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 - Substitution of addition u/s 269SS with 69A - unsecured loans - assessee engaged in banking business - Enhancement of tax liability u/s 115BBE - The ITAT Ahmedabad, after hearing both parties, found discrepancies in the application of sections 269SS and 69A to the cooperative bank's case. The rectification order was deemed a typographical error without proper verification. The ITAT directed the AO to reexamine the applicability of section 69A, ensuring proper evidence and hearing, and allowed the appeals partly for statistical purposes.
Rectification u/s 154 - Substitution of addition u/s 269SS with 69A - unsecured loans - assessee engaged in banking business - Enhancement of tax liability u/s 115BBE - The ITAT Ahmedabad, after hearing both parties, found discrepancies in the application of sections 269SS and 69A to the cooperative bank's case. The rectification order was deemed a typographical error without proper verification. The ITAT directed the AO to reexamine the applicability of section 69A, ensuring proper evidence and hearing, and allowed the appeals partly for statistical purposes.
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