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 271D for alleged acceptance of a cash loan was held unsustainable where the case rested only on a third-party statement recorded in search proceedings and loose papers found at another premises. The assessee consistently denied taking any cash loan, yet the Assessing Officer did not provide the incriminating material, related assessment details, or an opportunity to cross-examine the alleged lender. In the absence of independent corroborative evidence, the allegation was treated as conjecture; loose sheets and random entries were said to have no evidentiary value against a third person unless supported by admissible material and surrounding circumstances. The penalty was deleted.
Penalty under section 271D for alleged acceptance of a cash loan was held unsustainable where the case rested only on a third-party statement recorded in search proceedings and loose papers found at another premises. The assessee consistently denied taking any cash loan, yet the Assessing Officer did not provide the incriminating material, related assessment details, or an opportunity to cross-examine the alleged lender. In the absence of independent corroborative evidence, the allegation was treated as conjecture; loose sheets and random entries were said to have no evidentiary value against a third person unless supported by admissible material and surrounding circumstances. The penalty was deleted.
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