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...
Compounding of offences for delayed remittance of tax deducted at source under Sections 276B and 278B was restored where stipulated charges were not paid within the prescribed period but were subsequently deposited in full. Financial difficulties and the company's subsequent liquidation were treated as bona fide reasons for the delay. The High Court extended the payment period up to the actual date of deposit, set aside rejection of the compounding applications, and made the earlier compounding order effective until that date. Restoration remained subject to additional costs payable to the Department, which could seek withdrawal of the deposited compounding charges. A second compounding application was unnecessary.
Compounding of offences for delayed remittance of tax deducted at source under Sections 276B and 278B was restored where stipulated charges were not paid within the prescribed period but were subsequently deposited in full. Financial difficulties and the company's subsequent liquidation were treated as bona fide reasons for the delay. The High Court extended the payment period up to the actual date of deposit, set aside rejection of the compounding applications, and made the earlier compounding order effective until that date. Restoration remained subject to additional costs payable to the Department, which could seek withdrawal of the deposited compounding charges. A second compounding application was unnecessary.
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