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 - Notice issued on the basis of statement recorded during survey u/s 133A - The High court observed that the survey conducted led to several factual findings essential for initiating the proceedings u/s 148A. It was noted that the statement of one of the partners, was not the sole basis for the proceedings and that other evidence arising from the survey was also considered. The court also acknowledged that a statement was recorded under Section 131, which has the same powers as a civil court, including examining individuals under oath. - Consequently, High Court refused to interfere.
Reopening of assessment u/s 147 - Notice issued on the basis of statement recorded during survey u/s 133A - The High court observed that the survey conducted led to several factual findings essential for initiating the proceedings u/s 148A. It was noted that the statement of one of the partners, was not the sole basis for the proceedings and that other evidence arising from the survey was also considered. The court also acknowledged that a statement was recorded under Section 131, which has the same powers as a civil court, including examining individuals under oath. - Consequently, High Court refused to interfere.
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