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 grant of permission to the petitioner’s assessing authority, to re-assess the petitioner - The HC observed that, since, the assessing officer failed to make any specific order of assessment in terms of Section 29(6) of the Act till 30.09.2016, his powers to make the regular assessment stood exhausted. - The High court quashed the reassessment order dated 17.03.2021 and the permission granted for reassessment, deeming them nullities due to lack of jurisdiction and absence of a valid reason to believe that any part of the petitioner's turnover had escaped assessment.
Validity of grant of permission to the petitioner’s assessing authority, to re-assess the petitioner - The HC observed that, since, the assessing officer failed to make any specific order of assessment in terms of Section 29(6) of the Act till 30.09.2016, his powers to make the regular assessment stood exhausted. - The High court quashed the reassessment order dated 17.03.2021 and the permission granted for reassessment, deeming them nullities due to lack of jurisdiction and absence of a valid reason to believe that any part of the petitioner's turnover had escaped assessment.
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