Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Maintainability of appeal - low tax effect - the case was reopened on the basis of revenue audit objection and in such circumstances, the same would be covered under the exception mentioned in the Circular No.3/2018 of the CBDT - Tribunal ought to have decided the issue on merits rather than dismissing the appeal on the ground of low tax effect - Tribunal order set aside
Maintainability of appeal - low tax effect - the case was reopened on the basis of revenue audit objection and in such circumstances, the same would be covered under the exception mentioned in the Circular No.3/2018 of the CBDT - Tribunal ought to have decided the issue on merits rather than dismissing the appeal on the ground of low tax effect - Tribunal order set aside
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