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...
The Appellate Tribunal considered a case involving revision u/s 263 of the Act related to annuity payments made to LIC. The employer did not make the annuity payment; it was made on employees' request from VRS amount. The claim for exemption u/s 10(10CC) and u/s 10(10BB) was found incorrect as per PCIT's enquiry. AO allowed exemptions without verifying from the employer, leading to an erroneous order. The annuity amount paid to LIC was deemed taxable as salary per Supreme Court ruling. The AO's failure to conduct proper inquiries rendered the order prejudicial to revenue. Jurisdiction u/s 263 was upheld, dismissing the assessee's appeals.
The Appellate Tribunal considered a case involving revision u/s 263 of the Act related to annuity payments made to LIC. The employer did not make the annuity payment; it was made on employees' request from VRS amount. The claim for exemption u/s 10(10CC) and u/s 10(10BB) was found incorrect as per PCIT's enquiry. AO allowed exemptions without verifying from the employer, leading to an erroneous order. The annuity amount paid to LIC was deemed taxable as salary per Supreme Court ruling. The AO's failure to conduct proper inquiries rendered the order prejudicial to revenue. Jurisdiction u/s 263 was upheld, dismissing the assessee's appeals.
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