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 High Court addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
The High Court addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
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