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 original tax assessment order and directed the Deputy Commissioner to provide a hearing and issue a reasoned order considering the taxpayer's reply. The court held that the show cause notice remained valid and proceedings could continue beyond three months. The statutory provision under Section 75(3) allows issuance of remand orders within two years from the original order's communication. The challenge to the Section 74(5) notice was deemed without merit, resulting in the petition's dismissal with no substantial legal grounds supporting the taxpayer's contention.
HC quashed the original tax assessment order and directed the Deputy Commissioner to provide a hearing and issue a reasoned order considering the taxpayer's reply. The court held that the show cause notice remained valid and proceedings could continue beyond three months. The statutory provision under Section 75(3) allows issuance of remand orders within two years from the original order's communication. The challenge to the Section 74(5) notice was deemed without merit, resulting in the petition's dismissal with no substantial legal grounds supporting the taxpayer's contention.
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