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...
Non acceptance of fresh evidence submitted u/r 46A of the I. T. Rules by CIT(A) - Tribunal noted that, it is possible that in the transition, the ld.CIT(A)[NFAC] had not received copies of the additional evidence filed by assessee. - Consequently, the Tribunal held that, as the Faceless Appeal was a new concept to CIT(A) as well as Assessee, the error which has crept is a possible human error and restored the matter to ld.CIT(A) for denovo adjudication.
Non acceptance of fresh evidence submitted u/r 46A of the I. T. Rules by CIT(A) - Tribunal noted that, it is possible that in the transition, the ld.CIT(A)[NFAC] had not received copies of the additional evidence filed by assessee. - Consequently, the Tribunal held that, as the Faceless Appeal was a new concept to CIT(A) as well as Assessee, the error which has crept is a possible human error and restored the matter to ld.CIT(A) for denovo adjudication.
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