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...
The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
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