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...
Reassessment - disclouser of information - A parrot-like repetition of the statutory language without any substance would certainly not amount to satisfying the jurisdictional conditions but if coupled with the context is sufficiently capable of conveying the fact that there was failure on the part of the assessee, that should be sufficient compliance with the requirements of section 148(2) of the Act. - HC
Reassessment - disclouser of information - A parrot-like repetition of the statutory language without any substance would certainly not amount to satisfying the jurisdictional conditions but if coupled with the context is sufficiently capable of conveying the fact that there was failure on the part of the assessee, that should be sufficient compliance with the requirements of section 148(2) of the Act. - HC
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