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...
Validity of reopening of assessment was examined and the impugned reassessment order was quashed because the stated reasons for reopening did not align with the reasons in the order; the matter is remitted for fresh adjudication. The remand requires the assessing authority to afford the taxpayer another opportunity to file a detailed reply with supporting documents and to decide the matter on merits in accordance with law. The impugned order is to be treated as an addendum to the pre-assessment show cause notice and the petitioner must upload its reply when the portal permits; writ petition disposed.
Validity of reopening of assessment was examined and the impugned reassessment order was quashed because the stated reasons for reopening did not align with the reasons in the order; the matter is remitted for fresh adjudication. The remand requires the assessing authority to afford the taxpayer another opportunity to file a detailed reply with supporting documents and to decide the matter on merits in accordance with law. The impugned order is to be treated as an addendum to the pre-assessment show cause notice and the petitioner must upload its reply when the portal permits; writ petition disposed.
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