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 - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for reassessment under the Income Tax Act. The petitioner argued that the reassessment was based on a change of opinion rather than a mistake. The court examined the assessment procedure and found that the reasons for reopening the assessment did not indicate the discovery of new material but rather a potential change of opinion. - Consequently, the court quashed the impugned order and notice, ruling in favor of the petitioner.
Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for reassessment under the Income Tax Act. The petitioner argued that the reassessment was based on a change of opinion rather than a mistake. The court examined the assessment procedure and found that the reasons for reopening the assessment did not indicate the discovery of new material but rather a potential change of opinion. - Consequently, the court quashed the impugned order and notice, ruling in favor of the petitioner.
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