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...
Petitioner argued non-receipt of notices preceding impugned assessment orders. Partnership firm discontinued business, carried on by proprietor. Court held petitioner neglected intimating firm's dissolution, surrendering PAN. Transactions made from firm's account despite alleged proprietorship. Returns filed from firm's address. Huge transactions observed. Respondent rightfully passed order u/s 144 read with 147 due to non-reply. Petitioner individually assessed requiring detailed consideration. Court quashed impugned orders, treating them as addenda to show-cause notices. Petitioner to pre-deposit Rs. 50,00,000 within eight weeks to Income Tax Department. Opportunity granted to file reply.
Petitioner argued non-receipt of notices preceding impugned assessment orders. Partnership firm discontinued business, carried on by proprietor. Court held petitioner neglected intimating firm's dissolution, surrendering PAN. Transactions made from firm's account despite alleged proprietorship. Returns filed from firm's address. Huge transactions observed. Respondent rightfully passed order u/s 144 read with 147 due to non-reply. Petitioner individually assessed requiring detailed consideration. Court quashed impugned orders, treating them as addenda to show-cause notices. Petitioner to pre-deposit Rs. 50,00,000 within eight weeks to Income Tax Department. Opportunity granted to file reply.
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