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 Faceless assessment - procedure contemplated u/s 144B - The petitioner contended that their objections and replies were not considered before passing the assessment order, contrary to the procedures outlined in Section 144B(1)(vii), (xiv), and (xvi)(b) of the Act. The High Court found merit in this argument, noting that the failure to consider the petitioner's responses violated procedural requirements, thereby vitiating the assessment proceedings. - Matter restored back for fresh adjudication.
Validity of Faceless assessment - procedure contemplated u/s 144B - The petitioner contended that their objections and replies were not considered before passing the assessment order, contrary to the procedures outlined in Section 144B(1)(vii), (xiv), and (xvi)(b) of the Act. The High Court found merit in this argument, noting that the failure to consider the petitioner's responses violated procedural requirements, thereby vitiating the assessment proceedings. - Matter restored back for fresh adjudication.
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