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...
Reopening of assessment u/s 147 - The petitioner had initially failed to file income tax returns but later submitted various documents in response to notices received under the Income Tax Act. Despite this, the assessment order did not consider the documents submitted by the petitioner, nor did it provide reasons for the proposed variations. The court set aside the impugned order and remanded the matter to the tax authorities for reconsideration.
Reopening of assessment u/s 147 - The petitioner had initially failed to file income tax returns but later submitted various documents in response to notices received under the Income Tax Act. Despite this, the assessment order did not consider the documents submitted by the petitioner, nor did it provide reasons for the proposed variations. The court set aside the impugned order and remanded the matter to the tax authorities for reconsideration.
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