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 order passed u/s 147 - not providing any opportunity of hearing - Though this Court is very reluctant to interfere with any order u/s 143(3) or u/s 147 since the same is an appealable order but in this case admittedly the respondent Income Tax Authority has acted contrary to and in noncompliance of statutory provision of law and in view of this admitted legal and factual position, the aforesaid impugned order passed u/s 147 is set aside - HC
Validity of order passed u/s 147 - not providing any opportunity of hearing - Though this Court is very reluctant to interfere with any order u/s 143(3) or u/s 147 since the same is an appealable order but in this case admittedly the respondent Income Tax Authority has acted contrary to and in noncompliance of statutory provision of law and in view of this admitted legal and factual position, the aforesaid impugned order passed u/s 147 is set aside - HC
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