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 u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
Validity of Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
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