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...
Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
Section 142A permits a reference to the Valuation Officer only in the course of making an assessment or reassessment, and only where the Assessing Officer has material showing that the assessee's valuation is unreliable. The provision cannot be used to collect information for reopening assessment. Where the books of account are neither rejected nor found defective, the Assessing Officer cannot rely solely on the DVO's report to make additions. On these facts, the valuation reference made during reopening, and the additions based on it, were held unsustainable, and the Tribunal's order was affirmed.
Note: It is a system-generated summary and is for quick reference only.