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 - validity of reasons to believe - Information has to be such as is contemplated in the Explanation 1 to section 147 of the Act. In the present case, there is no observation of the AO that the material on record was embedded in such a manner that it was not possible for the AO to notice the same at the time of scrutiny assessment.
Reopening of assessment u/s 147 - validity of reasons to believe - Information has to be such as is contemplated in the Explanation 1 to section 147 of the Act. In the present case, there is no observation of the AO that the material on record was embedded in such a manner that it was not possible for the AO to notice the same at the time of scrutiny assessment.
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