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 - Deduction u/s 80IB(10) - built-up area of some of the residential units in the project was more than the prescribed area of 1000 sq. ft - the reopening of the case before us was carried out on the basis of fresh “tangible material” which clearly established that the A.O had a ‘reason to believe’ that the income of the assessee chargeable to tax had escaped assessment.
Reopening of assessment u/s 147 - Deduction u/s 80IB(10) - built-up area of some of the residential units in the project was more than the prescribed area of 1000 sq. ft - the reopening of the case before us was carried out on the basis of fresh “tangible material” which clearly established that the A.O had a ‘reason to believe’ that the income of the assessee chargeable to tax had escaped assessment.
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