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...
Rationalisation of Appeals to the Appellate Tribunal - as per the amendment to sec 253 revisional order passed u/s 263 by PCC or CC or an order u/s 154 are now appealable to Appellate Tribunal. Also, Memorandum of cross objection has been introduced for the revenue where in case respondent files appeal against the order of Commissioner (Appeals), like Principal Commissioner or Commissioner or Principal Director or Director etc. AO would be able to file a cross objection to such appeal which cannot be filed presently.
Rationalisation of Appeals to the Appellate Tribunal - as per the amendment to sec 253 revisional order passed u/s 263 by PCC or CC or an order u/s 154 are now appealable to Appellate Tribunal. Also, Memorandum of cross objection has been introduced for the revenue where in case respondent files appeal against the order of Commissioner (Appeals), like Principal Commissioner or Commissioner or Principal Director or Director etc. AO would be able to file a cross objection to such appeal which cannot be filed presently.
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