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 key points from the legal text are: Section 153A assessment - Limitation period applies based on when seized materials were handed over to the Assessing Officer (AO), not the search date. Despite 60-day limit in Section 132(9A) for handing over seized assets, non-adherence does not invalidate assessment if within extended limitation u/s 153B(1) proviso. Validity of satisfaction notes u/s 153C - Separate notes recorded for each year, concluding seized materials pertained to assessee and impacted income. Satisfied threshold u/s 153C(1) despite not explicitly mentioning all earlier years. Transfer order u/s 127 - Mixed questions of fact and law involved in determining if consent/consultation requirements were met. No findings recorded due to lack of pleadings. Addition u/s 69 read with 115BBE - Applicable for unexplained investments not recorded in books, even if no books maintained. Computation of income and tax liability upheld.
The key points from the legal text are: Section 153A assessment - Limitation period applies based on when seized materials were handed over to the Assessing Officer (AO), not the search date. Despite 60-day limit in Section 132(9A) for handing over seized assets, non-adherence does not invalidate assessment if within extended limitation u/s 153B(1) proviso. Validity of satisfaction notes u/s 153C - Separate notes recorded for each year, concluding seized materials pertained to assessee and impacted income. Satisfied threshold u/s 153C(1) despite not explicitly mentioning all earlier years. Transfer order u/s 127 - Mixed questions of fact and law involved in determining if consent/consultation requirements were met. No findings recorded due to lack of pleadings. Addition u/s 69 read with 115BBE - Applicable for unexplained investments not recorded in books, even if no books maintained. Computation of income and tax liability upheld.
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