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 u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
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