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...
Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was reopened u/s 147 after obtaining approval u/s 148, citing revision of assessee's entitlement to carry forward losses due to Section 79 application. Claims were examined during original assessment proceedings, and no error prejudicial to Revenue's interests was found. Inadequate inquiry by Assessing Officer regarding certain claims does not warrant invoking Section 263 powers. Revenue failed to establish that Commissioner exercised power in accordance with law. Facts do not fulfill twin conditions of Section 263. Decided in favor of assessee.
Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was reopened u/s 147 after obtaining approval u/s 148, citing revision of assessee's entitlement to carry forward losses due to Section 79 application. Claims were examined during original assessment proceedings, and no error prejudicial to Revenue's interests was found. Inadequate inquiry by Assessing Officer regarding certain claims does not warrant invoking Section 263 powers. Revenue failed to establish that Commissioner exercised power in accordance with law. Facts do not fulfill twin conditions of Section 263. Decided in favor of assessee.
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