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...
CIT(A) directed to first adjudicate assessee's appeal against quantum assessment, determine business turnover, and whether assessee falls within Section 44AB for audit obligation before adjudicating penalty u/s 271B for failure to furnish audit report. ITAT set aside CIT(A)'s order, restoring matter to CIT(A) for fresh adjudication in interest of justice and fairness. Assessee's appeal allowed for statistical purposes.
CIT(A) directed to first adjudicate assessee's appeal against quantum assessment, determine business turnover, and whether assessee falls within Section 44AB for audit obligation before adjudicating penalty u/s 271B for failure to furnish audit report. ITAT set aside CIT(A)'s order, restoring matter to CIT(A) for fresh adjudication in interest of justice and fairness. Assessee's appeal allowed for statistical purposes.
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