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 quashed the impugned notice u/s 148 for reopening of assessment. It held that since the petitioner had not directly received any remittances from the DSNE CGHS, there was no occasion for the petitioner to make a disclosure in its Return of Income. Consequently, the reason to believe for invoking Section 147 for reassessment was unsustainable. However, the Court left it open to the respondents to initiate proceedings afresh, if otherwise permissible in law.
The High Court quashed the impugned notice u/s 148 for reopening of assessment. It held that since the petitioner had not directly received any remittances from the DSNE CGHS, there was no occasion for the petitioner to make a disclosure in its Return of Income. Consequently, the reason to believe for invoking Section 147 for reassessment was unsustainable. However, the Court left it open to the respondents to initiate proceedings afresh, if otherwise permissible in law.
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