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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...
Revision u/s 263 - The Tribunal concluded that the assessing officer had conducted a reasonable inquiry into the relevant issues, and the assessment order was neither erroneous nor prejudicial to the interests of the Revenue. Despite the discrepancy between the intended scrutiny and the actual assessment, the Tribunal upheld the validity of the assessment order. Additionally, the Tribunal rejected the application of Instruction No. 9/2007, stating its inapplicability to the case at hand. - In light of the findings, the High Court dismissed the appeal, as it found no question of law arising from the impugned order.
Revision u/s 263 - The Tribunal concluded that the assessing officer had conducted a reasonable inquiry into the relevant issues, and the assessment order was neither erroneous nor prejudicial to the interests of the Revenue. Despite the discrepancy between the intended scrutiny and the actual assessment, the Tribunal upheld the validity of the assessment order. Additionally, the Tribunal rejected the application of Instruction No. 9/2007, stating its inapplicability to the case at hand. - In light of the findings, the High Court dismissed the appeal, as it found no question of law arising from the impugned order.
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