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...
HC quashed the order of CIT(Appeals) regarding a belated appeal filing, determining that the appeal submitted manually in Form No.35 on 15.06.2016 was valid under Circular No.20/2016. The court found the appeal's dismissal on grounds of delay was improper. The matter was remanded to CIT(Appeals) for a fresh hearing on merits, directing procedural fairness by providing the petitioner an opportunity to present their case in accordance with established legal principles.
HC quashed the order of CIT(Appeals) regarding a belated appeal filing, determining that the appeal submitted manually in Form No.35 on 15.06.2016 was valid under Circular No.20/2016. The court found the appeal's dismissal on grounds of delay was improper. The matter was remanded to CIT(Appeals) for a fresh hearing on merits, directing procedural fairness by providing the petitioner an opportunity to present their case in accordance with established legal principles.
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