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...
Revision u/s 263 by CIT - sale of impugned land measuring 10.162 acres below the stamp duty value - under the given circumstances, it can be safely concluded that the price realized by SBI is fair market value of land as on the date of sale - Where there are two possible views and the Assessing Officer has taken one of the possible views, no action to exercise powers of revision can arise, nor can revisional power be exercised for directing a fuller enquiry to find out if the view taken is erroneous. This power of revision can be exercised only where no enquiry, as required under the law, is done. - AT
Revision u/s 263 by CIT - sale of impugned land measuring 10.162 acres below the stamp duty value - under the given circumstances, it can be safely concluded that the price realized by SBI is fair market value of land as on the date of sale - Where there are two possible views and the Assessing Officer has taken one of the possible views, no action to exercise powers of revision can arise, nor can revisional power be exercised for directing a fuller enquiry to find out if the view taken is erroneous. This power of revision can be exercised only where no enquiry, as required under the law, is done. - AT
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