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...
Assessment u/s 153C - Since a response was on record, undoubtedly, the AO was required to issue a notice under Section 143(2) of the Act and then proceed further in the matter, and perhaps thereafter, frame an assessment u/s 147 read with Section 144 of the Act. This was not done. - for the AO to take recourse to Section 144 of the Act was completely uncalled. - HC
Assessment u/s 153C - Since a response was on record, undoubtedly, the AO was required to issue a notice under Section 143(2) of the Act and then proceed further in the matter, and perhaps thereafter, frame an assessment u/s 147 read with Section 144 of the Act. This was not done. - for the AO to take recourse to Section 144 of the Act was completely uncalled. - HC
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