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...
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
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