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 - Addition of unapproved purchases based on peak calculation - the aforesaid addition is not based on any incriminating documents or material found during the course of search, albeit is has been made on the basis of search conducted after more than 2 years in case of different persons and based on certain information received on 24.03.2014 - the same is outside purview and the addition made u/s 153A is unabated assessment. - AT
Assessment u/s 153A - Addition of unapproved purchases based on peak calculation - the aforesaid addition is not based on any incriminating documents or material found during the course of search, albeit is has been made on the basis of search conducted after more than 2 years in case of different persons and based on certain information received on 24.03.2014 - the same is outside purview and the addition made u/s 153A is unabated assessment. - AT
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