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...
A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not substitute recording satisfaction note by AO and handing over material for initiation of proceedings u/s 153C. No reference of asset representing escaped income, hence reopening for ten years u/s 153A not applicable. Notice issued beyond six years from end of AY 2014-15, beyond limitation period. HC allowed petition, set aside impugned notices u/s 148A(b) and 148, decided in favour of assessee.
A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not substitute recording satisfaction note by AO and handing over material for initiation of proceedings u/s 153C. No reference of asset representing escaped income, hence reopening for ten years u/s 153A not applicable. Notice issued beyond six years from end of AY 2014-15, beyond limitation period. HC allowed petition, set aside impugned notices u/s 148A(b) and 148, decided in favour of assessee.
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