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 reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
Validity of reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
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