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...
AO suo-moto framed the order u/s. 154 and rectified the order - AO framed order u/s. 154 of the Act without affording a reasonable and adequate opportunity of being heard to the assessee, also without being directed by CIT(A) - The Tribunal dismissed the appeal of the Revenue, stating that the AO assumed powers conferred upon him by section 154 of the Act without affording any opportunity of being heard to the assessee. Therefore, the Tribunal upheld the CIT(A)'s decision.
AO suo-moto framed the order u/s. 154 and rectified the order - AO framed order u/s. 154 of the Act without affording a reasonable and adequate opportunity of being heard to the assessee, also without being directed by CIT(A) - The Tribunal dismissed the appeal of the Revenue, stating that the AO assumed powers conferred upon him by section 154 of the Act without affording any opportunity of being heard to the assessee. Therefore, the Tribunal upheld the CIT(A)'s decision.
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