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 of mistake u/s 154 - period of limitation - the original assessment u/s 143(3) is dated 21.11.2011 - the order u/s 154 has been passed on 29.06.2017, which is clearly beyond the period of four years specified and therefore, the 154 order passed by the AO is beyond the period of the limitation provided. Accordingly, same is invalid in law and thus it is quashed. - AT
Rectification of mistake u/s 154 - period of limitation - the original assessment u/s 143(3) is dated 21.11.2011 - the order u/s 154 has been passed on 29.06.2017, which is clearly beyond the period of four years specified and therefore, the 154 order passed by the AO is beyond the period of the limitation provided. Accordingly, same is invalid in law and thus it is quashed. - AT
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