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...
Service and issuance of notice u/s 143(2) - scope of insertion of Section 292BB - for Section 292BB to apply, the notice must have emanated from the department, it is only the infirmities in the manner of service of notice that the Section seeks to cure - The Section is not intended to cure complete absence of notice itself - issuance of notice u/s 143(2) is mandatory
Service and issuance of notice u/s 143(2) - scope of insertion of Section 292BB - for Section 292BB to apply, the notice must have emanated from the department, it is only the infirmities in the manner of service of notice that the Section seeks to cure - The Section is not intended to cure complete absence of notice itself - issuance of notice u/s 143(2) is mandatory
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