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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...
The HC quashed the reassessment notice and consequential proceedings, holding that the reassessment action could not be sustained due to: (1) the alleged escaped income falling below the pecuniary threshold prescribed u/s 149(1)(b) as per the Supreme Court's ruling in Rajeev Bansal; and (2) the approval for reassessment not being granted by the competent authority u/s 151 after the introduction of the extended timelines by the Taxation Laws (Amendment) Act, 2021. The HC allowed the writ petition in favor of the assessee.
The HC quashed the reassessment notice and consequential proceedings, holding that the reassessment action could not be sustained due to: (1) the alleged escaped income falling below the pecuniary threshold prescribed u/s 149(1)(b) as per the Supreme Court's ruling in Rajeev Bansal; and (2) the approval for reassessment not being granted by the competent authority u/s 151 after the introduction of the extended timelines by the Taxation Laws (Amendment) Act, 2021. The HC allowed the writ petition in favor of the assessee.
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