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...
Reopening of assessment u/s 147 - tangible material with the respondent authority for recording satisfaction - when the department has not considered the objections raised by the petitioner for the reason that the petitioner company has failed to disclose fully and truly all the material facts necessary for his assessment for the year under consideration and when the AO has reason to believe that income chargeable to tax has escaped assessment, we are of the view that the above decision would be of no avail to the petitioner. - HC
Reopening of assessment u/s 147 - tangible material with the respondent authority for recording satisfaction - when the department has not considered the objections raised by the petitioner for the reason that the petitioner company has failed to disclose fully and truly all the material facts necessary for his assessment for the year under consideration and when the AO has reason to believe that income chargeable to tax has escaped assessment, we are of the view that the above decision would be of no avail to the petitioner. - HC
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