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...
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
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