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 - The High Court notes that certain incomes were raised for the first time in the impugned order, without prior mention. Despite Petitioner's explanations and evidence, the Assessing Officer (AO) failed to justify dissatisfaction with the disclosures. The Court concludes that the impugned order was passed without proper application of mind, as evident from the lack of scrutiny by higher authorities. Consequently, the Court quashes the impugned order and the notice issued under Section 148 of the Act.
Validity of reopening of assessment - The High Court notes that certain incomes were raised for the first time in the impugned order, without prior mention. Despite Petitioner's explanations and evidence, the Assessing Officer (AO) failed to justify dissatisfaction with the disclosures. The Court concludes that the impugned order was passed without proper application of mind, as evident from the lack of scrutiny by higher authorities. Consequently, the Court quashes the impugned order and the notice issued under Section 148 of the Act.
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