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 u/s 147 - order passed u/s 148A - It may be true that, the Petitioner would be having number of opportunities to explain his stand in the proceedings to be initiated under Section 148 of the Act, i.e., after filing of the assessment, but the argument of the learned Counsel for the Petitioner that the Petitioner could not be put to such a ordeal, at this stage, more so, when the Order came to be passed without verifying the records, cannot also be brushed aside. - matter restored back - HC
Validity of Reopening of assessment u/s 147 - order passed u/s 148A - It may be true that, the Petitioner would be having number of opportunities to explain his stand in the proceedings to be initiated under Section 148 of the Act, i.e., after filing of the assessment, but the argument of the learned Counsel for the Petitioner that the Petitioner could not be put to such a ordeal, at this stage, more so, when the Order came to be passed without verifying the records, cannot also be brushed aside. - matter restored back - HC
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