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...
Reopening of assessment - as alleged Petitioner was a beneficiary of accommodation entries - Notices under Section 148A(b) were issued, alleging escaped income, followed by a subsequent notice clarifying errors. - Petitioner's response, supported by evidence, was rejected for failure to submit documents not initially requested. - The High Court quashed the rejection order and remanded the matter for reconsideration. The assessing officer was directed to provide a reasoned decision and justify the rejection of petitioner's evidence.
Reopening of assessment - as alleged Petitioner was a beneficiary of accommodation entries - Notices under Section 148A(b) were issued, alleging escaped income, followed by a subsequent notice clarifying errors. - Petitioner's response, supported by evidence, was rejected for failure to submit documents not initially requested. - The High Court quashed the rejection order and remanded the matter for reconsideration. The assessing officer was directed to provide a reasoned decision and justify the rejection of petitioner's evidence.
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