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 for initial non-compliance with notices under section 142(1) was treated as unsustainable where the assessee later furnished replies and documentary evidence during assessment, and the return was accepted under section 143(3) without adverse inference. The assessment order recorded verification of the later compliance and found it tenable, which indicated that the earlier default had been effectively condoned. On the same facts, the same reasoning was applied to the connected matters, and the penalty under section 272A(1)(d) was deleted.
Penalty for initial non-compliance with notices under section 142(1) was treated as unsustainable where the assessee later furnished replies and documentary evidence during assessment, and the return was accepted under section 143(3) without adverse inference. The assessment order recorded verification of the later compliance and found it tenable, which indicated that the earlier default had been effectively condoned. On the same facts, the same reasoning was applied to the connected matters, and the penalty under section 272A(1)(d) was deleted.
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