Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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 ITAT affirmed that the assessee, a foreign company incorporated in the British Virgin Islands, qualified as an "eligible assessee" under section 144C(15)(b) and thus the AO was statutorily obliged to issue a draft assessment under section 144C(1). The AO proceeded to pass final assessment orders without issuing the mandated draft, rendering the final orders vitiated for non-compliance with the mandatory pre-draft procedure. The CIT(A)'s decision setting aside the impugned final assessments was upheld, and the Revenue's appeal was dismissed. The matter is remitted for fresh proceedings in accordance with the statutory scheme under section 144C.
The ITAT affirmed that the assessee, a foreign company incorporated in the British Virgin Islands, qualified as an "eligible assessee" under section 144C(15)(b) and thus the AO was statutorily obliged to issue a draft assessment under section 144C(1). The AO proceeded to pass final assessment orders without issuing the mandated draft, rendering the final orders vitiated for non-compliance with the mandatory pre-draft procedure. The CIT(A)'s decision setting aside the impugned final assessments was upheld, and the Revenue's appeal was dismissed. The matter is remitted for fresh proceedings in accordance with the statutory scheme under section 144C.
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