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...
Reopening of assessment u/s 147 - 'reason to believe' or 'reason to suspect' - objections of the petitioner were rejected by a non-speaking and cryptic order - information already available on record - merely because there is a change in opinion, reopening could not have been done
Reopening of assessment u/s 147 - 'reason to believe' or 'reason to suspect' - objections of the petitioner were rejected by a non-speaking and cryptic order - information already available on record - merely because there is a change in opinion, reopening could not have been done
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