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 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the assessee to tell as to how the Assessing Officer has to complete the assessment. - It would be a clear case of change of opinion. What the Assessing Officer purported to do is to review his earlier decision. - proceedings of reopening quashed - HC
Reopening of assessment u/s 147 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the assessee to tell as to how the Assessing Officer has to complete the assessment. - It would be a clear case of change of opinion. What the Assessing Officer purported to do is to review his earlier decision. - proceedings of reopening quashed - HC
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