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...
Rectification u/s 154 - period of limitation - original order passed by the AO dated 05/04/2011 - AO has already passed a suo-moto rectification order u/s 154 dated 18/03/2014 - Even though the surcharge was levied in terms of the first order, the order so sought to be rectified by the assessee is the rectified order dated 18/03/2014 wherein the surcharge continued to be levied on the assessee besides additional interest. Therefore, the rectification application dated 01/07/2016 is well within the limitation period as so prescribed and is not barred by limitation. - AT
Rectification u/s 154 - period of limitation - original order passed by the AO dated 05/04/2011 - AO has already passed a suo-moto rectification order u/s 154 dated 18/03/2014 - Even though the surcharge was levied in terms of the first order, the order so sought to be rectified by the assessee is the rectified order dated 18/03/2014 wherein the surcharge continued to be levied on the assessee besides additional interest. Therefore, the rectification application dated 01/07/2016 is well within the limitation period as so prescribed and is not barred by limitation. - AT
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