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...
Faceless assessment u/s 144B(1)(xvi)(a) - draft order was not prepared - However, an income or loss determination proposal was prepared. - the best way forward would be to set aside the impugned assessment order, with liberty to the Assessing Officer (AO) to conduct the proceedings de novo, after according personal hearing to the petitioner/assessee and/or his authorised representative. - HC
Faceless assessment u/s 144B(1)(xvi)(a) - draft order was not prepared - However, an income or loss determination proposal was prepared. - the best way forward would be to set aside the impugned assessment order, with liberty to the Assessing Officer (AO) to conduct the proceedings de novo, after according personal hearing to the petitioner/assessee and/or his authorised representative. - HC
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