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 o Ex parte scrutiny assessment order u/s 143(3) r.w.s. 144B - The court highlighted the importance of oral hearing in assessment proceedings, stating that it is essential for an effective discussion and a reasoned conclusion by the Assessing Officer. It was emphasized that assessment orders should be passed after giving the assessee an opportunity to present their case, and oral hearing remains a near-mandatory requirement to ensure a just and proper order.
Validity of o Ex parte scrutiny assessment order u/s 143(3) r.w.s. 144B - The court highlighted the importance of oral hearing in assessment proceedings, stating that it is essential for an effective discussion and a reasoned conclusion by the Assessing Officer. It was emphasized that assessment orders should be passed after giving the assessee an opportunity to present their case, and oral hearing remains a near-mandatory requirement to ensure a just and proper order.
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