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...
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
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