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 - Shorter time to reply to notice - As an order passed under Section 147 of the Income Tax Act, 1961 is an appealable order, in terms of Section 246 (i)(b) of the Income Tax Act, 1961, it is the opinion of the Court that the petitioner can avail the alternative remedy available by approaching the appellate authority. However, keeping in view the fact that the petitioner has been given only 2 (two) days time to file a reply to the show cause notice dated 25.03.2022, this Court is of the view that the respondents should give the petitioner a further 10 (ten) days time from today, for filing his reply to the show cause notice dated 25.03.2022 - HC
Reopening of assessment u/s 147 - Shorter time to reply to notice - As an order passed under Section 147 of the Income Tax Act, 1961 is an appealable order, in terms of Section 246 (i)(b) of the Income Tax Act, 1961, it is the opinion of the Court that the petitioner can avail the alternative remedy available by approaching the appellate authority. However, keeping in view the fact that the petitioner has been given only 2 (two) days time to file a reply to the show cause notice dated 25.03.2022, this Court is of the view that the respondents should give the petitioner a further 10 (ten) days time from today, for filing his reply to the show cause notice dated 25.03.2022 - HC
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