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...
Validity of Revision u/s 263 - non mentioning computer generated DIN - Non-est order - Circular categorically mentions that subsequent to 01/10/2019, the computer generated DIN not only be allotted but be duly quoted in the body of the communication itself. - Neither the reasons nor the statement in the prescribed format is to be found in the order passed u/s 263 of the Act, spelling out the particular category of exception that prevented allotting the DIN on that day. It is yet another violation. - such an order shall be treated to have never been issued and, therefore, shall not take any affect. - AT
Validity of Revision u/s 263 - non mentioning computer generated DIN - Non-est order - Circular categorically mentions that subsequent to 01/10/2019, the computer generated DIN not only be allotted but be duly quoted in the body of the communication itself. - Neither the reasons nor the statement in the prescribed format is to be found in the order passed u/s 263 of the Act, spelling out the particular category of exception that prevented allotting the DIN on that day. It is yet another violation. - such an order shall be treated to have never been issued and, therefore, shall not take any affect. - AT
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