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...
Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
