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 Settlement Commission orders - The case involved petitions seeking directives for the issuance of formal orders under section 245D (4) of the Income Tax Act, 1961, reflecting settlement terms pronounced by the Settlement Commission. While petitioners asserted the settlement's conclusion, respondent No. 2 contested, citing discrepancies in official records. - Upon review, the High Court found the affidavit of the Vice President and Member of the Settlement Commission to be conclusive evidence of settlement. Despite respondent No. 2's objections, the High Court directed the Interim Board to issue the requested orders, ensuring the proper administration of justice.
Validity of Settlement Commission orders - The case involved petitions seeking directives for the issuance of formal orders under section 245D (4) of the Income Tax Act, 1961, reflecting settlement terms pronounced by the Settlement Commission. While petitioners asserted the settlement's conclusion, respondent No. 2 contested, citing discrepancies in official records. - Upon review, the High Court found the affidavit of the Vice President and Member of the Settlement Commission to be conclusive evidence of settlement. Despite respondent No. 2's objections, the High Court directed the Interim Board to issue the requested orders, ensuring the proper administration of justice.
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