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...
Section 154 rectification order reversing previous order on allowance of depreciation on non-compete fee cannot be invoked when the issue is debatable. Primary issue pending consideration before Supreme Court. Jurisdictional High Court admitted whether Section 154 powers can be exercised when the issue is debatable in assessee's own case for earlier assessment year. Considering High Court admission of identical question in assessee's case, for judicial discipline and propriety, impugned order set aside, issue restored to CIT(Appeals) to decide after outcome of assessee's own case for AY 2012-13 and pass order accordingly. Appeal allowed for statistical purposes.
Section 154 rectification order reversing previous order on allowance of depreciation on non-compete fee cannot be invoked when the issue is debatable. Primary issue pending consideration before Supreme Court. Jurisdictional High Court admitted whether Section 154 powers can be exercised when the issue is debatable in assessee's own case for earlier assessment year. Considering High Court admission of identical question in assessee's case, for judicial discipline and propriety, impugned order set aside, issue restored to CIT(Appeals) to decide after outcome of assessee's own case for AY 2012-13 and pass order accordingly. Appeal allowed for statistical purposes.
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