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...
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
