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 reopening of assessment - Non-issuance of notice u/s. 148 - Once it is proved that notice u/s.148 was not issued, there cannot be any question of making any reassessment. Reliance of CIT(A) on the provisions of section 292BB is misplaced because the said section only stipulates that participation in the assessment proceedings/reassessment proceedings would be deemed as a proper service of notice. - AT
Validity of reopening of assessment - Non-issuance of notice u/s. 148 - Once it is proved that notice u/s.148 was not issued, there cannot be any question of making any reassessment. Reliance of CIT(A) on the provisions of section 292BB is misplaced because the said section only stipulates that participation in the assessment proceedings/reassessment proceedings would be deemed as a proper service of notice. - AT
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