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 - reasons to believe - “tangible material” - There is no whisper in the impugned reassessment order as to how the AO has arrived at the aforesaid amount as undisclosed income and that how the aforesaid amount represents undisclosed income of the petitioner/assessee. Thus the reassessment proceeding initiated by the AO against the petitioner for the AY 2017-18 was not only without jurisdiction but also it was abuse of power - HC
Reopening of assessment u/s 147 - reasons to believe - “tangible material” - There is no whisper in the impugned reassessment order as to how the AO has arrived at the aforesaid amount as undisclosed income and that how the aforesaid amount represents undisclosed income of the petitioner/assessee. Thus the reassessment proceeding initiated by the AO against the petitioner for the AY 2017-18 was not only without jurisdiction but also it was abuse of power - HC
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