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...
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
Dispute concerns entitlement to interest on delayed refund where the assessing officer denied interest by alleging a lapse in claiming TDS in a revised return. The legal principle stated is that exclusion of any period for calculating interest must be determined by the authority designated under the relevant statute; the AO lacks power to unilaterally disallow interest on that ground. The AO's terse finding was treated as erroneous; the appellate authority accepted the taxpayer's explanation regarding Form 26AS and held there was no lapse in claiming the credit.
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