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...
Validity of assessment - non issuance of a show cause notice-cum-draft assessment order; which is a mandatory requirement u/s 144B - The impugned assessment order dated 30.04.2021, as also the notice of demand issued under Section 156 of the Act, and notice for initiation of penalty proceedings issued under Section 270A of the Act, of even date, shall stand set aside. - HC
Validity of assessment - non issuance of a show cause notice-cum-draft assessment order; which is a mandatory requirement u/s 144B - The impugned assessment order dated 30.04.2021, as also the notice of demand issued under Section 156 of the Act, and notice for initiation of penalty proceedings issued under Section 270A of the Act, of even date, shall stand set aside. - HC
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