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...
Scope of Rectification u/s 254 - Power of ITAT - valuation of a bundle of sports rights purchased by the petitioner - Despite detailed expert opinions and submissions by the petitioner, the Tribunal opted for a blanket remand to the TPO for fresh valuation, without addressing key issues raised by the petitioner. - The High Court referenced previous judgments, emphasizing the duty of the Tribunal to consider all factual and legal issues before remanding cases. - The Court highlighted the mistake apparent from the record, emphasizing that the Tribunal's failure to address fundamental submissions made by the petitioner warranted rectification of the order. - Matter restored back before the Tribunal.
Scope of Rectification u/s 254 - Power of ITAT - valuation of a bundle of sports rights purchased by the petitioner - Despite detailed expert opinions and submissions by the petitioner, the Tribunal opted for a blanket remand to the TPO for fresh valuation, without addressing key issues raised by the petitioner. - The High Court referenced previous judgments, emphasizing the duty of the Tribunal to consider all factual and legal issues before remanding cases. - The Court highlighted the mistake apparent from the record, emphasizing that the Tribunal's failure to address fundamental submissions made by the petitioner warranted rectification of the order. - Matter restored back before the Tribunal.
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