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...
Income-tax Officer (Intelligence) authority to issue notice u/s 133(6) - Jurisdiction of Income Tax Authorities u/s 120 - From the reliance on the notification dated November 1, 2011, it is decipherable that the power of collection, collation and dissemination which earlier vested with Central Information Branch was transferred to Income-tax Officer (Intelligence), which would not mean that the notices issued and imposition of penalty by the Income-tax Officer (Intelligence) lacked jurisdiction. - HC
Income-tax Officer (Intelligence) authority to issue notice u/s 133(6) - Jurisdiction of Income Tax Authorities u/s 120 - From the reliance on the notification dated November 1, 2011, it is decipherable that the power of collection, collation and dissemination which earlier vested with Central Information Branch was transferred to Income-tax Officer (Intelligence), which would not mean that the notices issued and imposition of penalty by the Income-tax Officer (Intelligence) lacked jurisdiction. - HC
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