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 - requirement to issue show cause notice u/s 263 - denial of natural justice - We do not agree with the contention of the ld Counsel to the effect that ld PCIT can give direction to the assessing officer in respect of those issues which are part of his show cause notice under section 263 - there is no requirement to issue notice under section 263 of the Act. The requirement under section 263 of the Act, is to give an opportunity of hearing only - AT
Revision u/s 263 - requirement to issue show cause notice u/s 263 - denial of natural justice - We do not agree with the contention of the ld Counsel to the effect that ld PCIT can give direction to the assessing officer in respect of those issues which are part of his show cause notice under section 263 - there is no requirement to issue notice under section 263 of the Act. The requirement under section 263 of the Act, is to give an opportunity of hearing only - AT
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