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 reviewed an assessment order challenged for being unreasoned. The Court found that the order lacked proper reasoning as it confirmed the tax proposal without explanation, rendering it unsustainable. The order was set aside, and the case remanded for reconsideration. The respondent was instructed to grant the taxpayer a fair opportunity, including a personal hearing, and issue a new order within three months. Consequently, the bank attachment linked to the assessment order was lifted. The petition was disposed of through remand.
The High Court reviewed an assessment order challenged for being unreasoned. The Court found that the order lacked proper reasoning as it confirmed the tax proposal without explanation, rendering it unsustainable. The order was set aside, and the case remanded for reconsideration. The respondent was instructed to grant the taxpayer a fair opportunity, including a personal hearing, and issue a new order within three months. Consequently, the bank attachment linked to the assessment order was lifted. The petition was disposed of through remand.
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