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 - period of limitation - whether the assessment order for AY 2015-16, issued on 31st March, 2023, was barred by the limitation prescribed in Section 153B? - The Supreme court noted that the impugned order was passed by the High Court without issuing a formal notice to the respondent-Department or calling for a response from them, despite the standing counsel for the Department being present in Court. - Considering this, the court disposed of the special leave petition, reserving liberty for the petitioner to raise contentions regarding jurisdictional error in relation to the limitation period before the appropriate authority.
Revision u/s 263 - period of limitation - whether the assessment order for AY 2015-16, issued on 31st March, 2023, was barred by the limitation prescribed in Section 153B? - The Supreme court noted that the impugned order was passed by the High Court without issuing a formal notice to the respondent-Department or calling for a response from them, despite the standing counsel for the Department being present in Court. - Considering this, the court disposed of the special leave petition, reserving liberty for the petitioner to raise contentions regarding jurisdictional error in relation to the limitation period before the appropriate authority.
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