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 u/s 153A - Undisclosed sales - CIT(A) had made detailed discussion on facts and recorded the finding that no incriminating evidence material was found during the course of search operation and also the contention of the learned Counsel for the assessee that letters relied upon by Assessing Officer were not made available to assessee during the course of assessment proceedings and to the CIT(A) during the course of appeal hearings as such on that basis, ld. CIT(A) should have also deleted the addition of undisclosed sales - Decided in favour of assessee. - AT
Assessment u/s 153A - Undisclosed sales - CIT(A) had made detailed discussion on facts and recorded the finding that no incriminating evidence material was found during the course of search operation and also the contention of the learned Counsel for the assessee that letters relied upon by Assessing Officer were not made available to assessee during the course of assessment proceedings and to the CIT(A) during the course of appeal hearings as such on that basis, ld. CIT(A) should have also deleted the addition of undisclosed sales - Decided in favour of assessee. - AT
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