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 u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
Rectification u/s 154 - disallowance of carrying forward of the loss - The High Court examined the contentions of both parties and found merit in the petitioner's argument regarding the violation of Section 154(3) of the Act. It emphasized that any rectification adversely affecting the assessee's interests must be preceded by a notice and an opportunity to be heard. Since such compliance was lacking in the impugned order, the Court deemed it unsustainable and set it aside.
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