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...
Rejection of application filed in form no. 10AB for grant of registration u/s 12AB and 80G(5) - The ITAT found that the CIT(E) had grounds for dissatisfaction based on the deficiencies and non-compliances reported by the CAG. However, the material effect of these issues on the Assessee's objectives was not explicitly addressed. The matter was remanded to the CIT(E) for a detailed examination and to provide a reasoned decision on whether these issues affect the Assessee's eligibility for registration under sections 12AB and 80G.
Rejection of application filed in form no. 10AB for grant of registration u/s 12AB and 80G(5) - The ITAT found that the CIT(E) had grounds for dissatisfaction based on the deficiencies and non-compliances reported by the CAG. However, the material effect of these issues on the Assessee's objectives was not explicitly addressed. The matter was remanded to the CIT(E) for a detailed examination and to provide a reasoned decision on whether these issues affect the Assessee's eligibility for registration under sections 12AB and 80G.
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