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...
Reopening of assessment u/s 147 - Decision concerning leases was delivered in the year 2014. Till that time neither the assessee nor the Assessing Officer had knowledge that such leases were illegal after 22.11.2007. When assessee was not knowing, there was no occasion for him to make disclosure to that effect. - The reassessment notices under Section 148 of the Income Tax Act for the years 2008-09 and 2011-12 were quashed due to the failure of the Assessing Officer to meet the necessary legal conditions, including the lack of independent verification and inquiry, and the inapplicability of the additional conditions required for reassessment beyond four years. - HC
Reopening of assessment u/s 147 - Decision concerning leases was delivered in the year 2014. Till that time neither the assessee nor the Assessing Officer had knowledge that such leases were illegal after 22.11.2007. When assessee was not knowing, there was no occasion for him to make disclosure to that effect. - The reassessment notices under Section 148 of the Income Tax Act for the years 2008-09 and 2011-12 were quashed due to the failure of the Assessing Officer to meet the necessary legal conditions, including the lack of independent verification and inquiry, and the inapplicability of the additional conditions required for reassessment beyond four years. - HC
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