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...
A penalty notice under section 270A must specify the precise limb of charge to be valid; a notice that fails to disclose whether the penalty is proposed for the applicable specific default is vague and unsustainable in law. Applying this principle, the Tribunal held that the notice was void ab initio because it did not mention the particular limb under which penalty was initiated, and the consequential penalty order was also liable to be quashed.
A penalty notice under section 270A must specify the precise limb of charge to be valid; a notice that fails to disclose whether the penalty is proposed for the applicable specific default is vague and unsustainable in law. Applying this principle, the Tribunal held that the notice was void ab initio because it did not mention the particular limb under which penalty was initiated, and the consequential penalty order was also liable to be quashed.
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