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...
Period of limitation to pass assessment order in case of remand proceedings u/s 153 - An order of any Court means an order of any and every Court of the country. - The hierarchy in status of the Court in the country is not decisive. As provided in Section 153(6) of the Act, that there must be a Court, and there must be an order of the Court. Therefore, when this Court remands the matter, it is an order of the Court which would extend the limitation for completing the assessment by the Assessing Officer for another twelve months. - HC
Period of limitation to pass assessment order in case of remand proceedings u/s 153 - An order of any Court means an order of any and every Court of the country. - The hierarchy in status of the Court in the country is not decisive. As provided in Section 153(6) of the Act, that there must be a Court, and there must be an order of the Court. Therefore, when this Court remands the matter, it is an order of the Court which would extend the limitation for completing the assessment by the Assessing Officer for another twelve months. - HC
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