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 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
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