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...
Parallel reassessment proceedings under sections 147/148 did not invalidate validly initiated section 153C proceedings, because the Tribunal found no legal basis to quash section 153C merely due to non-dropping of reassessment action. However, satisfaction for invoking section 153C must be recorded without inordinate delay, and recording it nearly four years after the search was held unjustified. On that ground, the Tribunal quashed the section 153C proceedings for both assessment years, applying the same delay finding where the search date and notice date were identical.
Parallel reassessment proceedings under sections 147/148 did not invalidate validly initiated section 153C proceedings, because the Tribunal found no legal basis to quash section 153C merely due to non-dropping of reassessment action. However, satisfaction for invoking section 153C must be recorded without inordinate delay, and recording it nearly four years after the search was held unjustified. On that ground, the Tribunal quashed the section 153C proceedings for both assessment years, applying the same delay finding where the search date and notice date were identical.
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