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...
Rectification u/s 154 - claim the allowance of 50% of the expenses against the commission income - Since the assessee has himself not pressed the issue as to allowability of 50% of the expenses against the income earned in the original appeal filed before the Tribunal vide appeal for for A.Y. 2004-05 to A.Y 2010-11 decided against which miscellaneous application has also been dismissed, he is not entitled to re-agitate the same issue before the Tribuanl under the garb of filing application under section 154 of the Act before the AO and then filling the appeal before the Ld. CIT(A) and the Tribunal. - AT
Rectification u/s 154 - claim the allowance of 50% of the expenses against the commission income - Since the assessee has himself not pressed the issue as to allowability of 50% of the expenses against the income earned in the original appeal filed before the Tribunal vide appeal for for A.Y. 2004-05 to A.Y 2010-11 decided against which miscellaneous application has also been dismissed, he is not entitled to re-agitate the same issue before the Tribuanl under the garb of filing application under section 154 of the Act before the AO and then filling the appeal before the Ld. CIT(A) and the Tribunal. - AT
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