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 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds for considering an order as erroneous and prejudicial to the interests of the revenue - The tribunal found the section 263 order to be unjustifiable for multiple reasons, including the absence of a clear failure by the assessee to disclose fully and truly all material facts necessary for its assessment, and quashed the order. - Revision order quashed.
Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds for considering an order as erroneous and prejudicial to the interests of the revenue - The tribunal found the section 263 order to be unjustifiable for multiple reasons, including the absence of a clear failure by the assessee to disclose fully and truly all material facts necessary for its assessment, and quashed the order. - Revision order quashed.
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