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...
Transfer of case u/s 127 - the assessee did not file any reply against the proposed centralisation under section 127 of the Act. It also became undisputed that the petitioner has not been given any opportunity of hearing. Drawing of conclusion by the authorities that the assessee had no objection on such proposed transfer, not only violated the basic principle of natural justice which are incorporated in section 127 itself - HC
Transfer of case u/s 127 - the assessee did not file any reply against the proposed centralisation under section 127 of the Act. It also became undisputed that the petitioner has not been given any opportunity of hearing. Drawing of conclusion by the authorities that the assessee had no objection on such proposed transfer, not only violated the basic principle of natural justice which are incorporated in section 127 itself - HC
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