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...
Assessment completed u/s 153C - Limitation for completion of assessment - Correct date of search - once it is held that the present assessment year i.e., A.Y 2014-15 is the year of search, then the limitation for completion of assessment in the instant case expires on 31.03.2016. - Since the AO in the instant case has passed the order on 30.08.2016, therefore, the same is barred by limitation. - AT
Assessment completed u/s 153C - Limitation for completion of assessment - Correct date of search - once it is held that the present assessment year i.e., A.Y 2014-15 is the year of search, then the limitation for completion of assessment in the instant case expires on 31.03.2016. - Since the AO in the instant case has passed the order on 30.08.2016, therefore, the same is barred by limitation. - AT
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