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 153C could not be invoked where the satisfaction note relied only on documents said to belong to the assessee but did not show that they were incriminating or relevant to the assessment year in question; the proceedings were therefore invalid. On the taxability of the land sale, a solitary sale of agricultural land was not treated as an adventure in the nature of trade, and rural agricultural land outside section 2(14)(iii) remained outside the capital asset definition. The Revenue could not convert the transaction into business income merely by referring to the purchaser's later non-agricultural use of the land. The addition was held unsustainable.
Section 153C could not be invoked where the satisfaction note relied only on documents said to belong to the assessee but did not show that they were incriminating or relevant to the assessment year in question; the proceedings were therefore invalid. On the taxability of the land sale, a solitary sale of agricultural land was not treated as an adventure in the nature of trade, and rural agricultural land outside section 2(14)(iii) remained outside the capital asset definition. The Revenue could not convert the transaction into business income merely by referring to the purchaser's later non-agricultural use of the land. The addition was held unsustainable.
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