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...
Validity of reopening proceedings - assessing authority not considering the reply-cum-objection filed by the petitioner - Period of limitation where monetary limit is below threshold of Rs. 50 lakhs - Joint Ownership of the property - The High Court quashed the entire enquiry proceeding, including the order under section 148A(d) of the Act and the notice issued under Section 148, deeming them beyond jurisdiction and barred by limitation. The court allowed the petitioner's application, emphasizing the procedural lapses and the incorrect application of the law by the tax department in this case.
Validity of reopening proceedings - assessing authority not considering the reply-cum-objection filed by the petitioner - Period of limitation where monetary limit is below threshold of Rs. 50 lakhs - Joint Ownership of the property - The High Court quashed the entire enquiry proceeding, including the order under section 148A(d) of the Act and the notice issued under Section 148, deeming them beyond jurisdiction and barred by limitation. The court allowed the petitioner's application, emphasizing the procedural lapses and the incorrect application of the law by the tax department in this case.
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