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 the ld. PCIT - Neither the AO had enquired into the sources of cash deposits nor the appellant had offered any explanation in support of the sources for cash deposits. This clearly goes to prove the AO had failed to examine this issue during the course of original assessment proceedings, which rendered the assessment order erroneous and prejudicial to the interests of the Revenue. - AT
Revision u/s 263 by the ld. PCIT - Neither the AO had enquired into the sources of cash deposits nor the appellant had offered any explanation in support of the sources for cash deposits. This clearly goes to prove the AO had failed to examine this issue during the course of original assessment proceedings, which rendered the assessment order erroneous and prejudicial to the interests of the Revenue. - AT
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