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...
Revision u/s 263 - addition u/s. 68 - This is not a case of non-enquiry or non-application of mind. The Assessing Officer has examined all the evidences and taken a possible view. Just because the total income determined by the Assessing Officer in the second round of assessment proceedings, is less than the income determined in the first assessment proceedings, the order does not become erroneous. - AT
Revision u/s 263 - addition u/s. 68 - This is not a case of non-enquiry or non-application of mind. The Assessing Officer has examined all the evidences and taken a possible view. Just because the total income determined by the Assessing Officer in the second round of assessment proceedings, is less than the income determined in the first assessment proceedings, the order does not become erroneous. - AT
Note: It is a system-generated summary and is for quick reference only.