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 - Discrepancy in the claim of imported purchases as per the books and as per the CBEC data - assessee was only put to notice about the mismatch in import purchases. The issue of mismatch in export sales never being confronted to the assessee, the Ld.PCIT’s order holding the assessment order erroneous on this count is against all principles of natural justice and accordingly is set aside on this count. - AT
Revision u/s 263 by CIT - Discrepancy in the claim of imported purchases as per the books and as per the CBEC data - assessee was only put to notice about the mismatch in import purchases. The issue of mismatch in export sales never being confronted to the assessee, the Ld.PCIT’s order holding the assessment order erroneous on this count is against all principles of natural justice and accordingly is set aside on this count. - AT
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