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 assessment order u/s. 147 r.w.s 144 - Assessee being Non-Resident Indian - The AO assessed the property below its market value, leading to an addition of income from other sources. The appellant contested this assessment, alleging procedural lapses including the failure to consider evidence and the non-referral of the matter to the Valuation Officer. Additionally, objections raised before the DRP were not adequately addressed. The Tribunal remitted the matter back to the AO for de novo consideration, granting the appellant another opportunity to present their case.
Validity of assessment order u/s. 147 r.w.s 144 - Assessee being Non-Resident Indian - The AO assessed the property below its market value, leading to an addition of income from other sources. The appellant contested this assessment, alleging procedural lapses including the failure to consider evidence and the non-referral of the matter to the Valuation Officer. Additionally, objections raised before the DRP were not adequately addressed. The Tribunal remitted the matter back to the AO for de novo consideration, granting the appellant another opportunity to present their case.
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