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...
Rectification of mistake u/s 154 - limited scrutiny of “Agricultural Income” - The High Court deliberated on the challenge to an Impugned Notice issued u/s 154 - It examined the contentions of both parties regarding the jurisdiction of the Assessing Officer and the scope of rectification u/s 154. Finding that certain issues raised in the notice were not addressed in the original Assessment Order, the Court affirmed the jurisdiction of the Assessing Officer to rectify such errors. It emphasized that the power to rectify extends to mistakes of fact or law apparent from the record. Ultimately, the Court dismissed the writ petition, upholding the validity of the Impugned Notice and allowing for further proceedings.
Rectification of mistake u/s 154 - limited scrutiny of “Agricultural Income” - The High Court deliberated on the challenge to an Impugned Notice issued u/s 154 - It examined the contentions of both parties regarding the jurisdiction of the Assessing Officer and the scope of rectification u/s 154. Finding that certain issues raised in the notice were not addressed in the original Assessment Order, the Court affirmed the jurisdiction of the Assessing Officer to rectify such errors. It emphasized that the power to rectify extends to mistakes of fact or law apparent from the record. Ultimately, the Court dismissed the writ petition, upholding the validity of the Impugned Notice and allowing for further proceedings.
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