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 proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.
Penalty proceedings for underreporting are independent of assessment proceedings. Failure to initiate penalty proceedings under section 270A while completing a reassessment does not, by itself, make the assessment order erroneous or prejudicial to the interests of the Revenue for revisional purposes. Revisional jurisdiction was therefore held unjustified where it rested solely on that omission, and the revisional order was quashed. A contrary Tribunal decision relied upon by the Revenue was distinguished. The assessee's appeal succeeded.
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