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 immunity under the Direct Tax Vivad Se Vishwas Scheme does not extend to an independent penalty for failure to obtain a statutory tax audit merely because related quantum additions were settled. The penalty issue remains separately examinable. For futures and options transactions, tax-audit applicability depends on evidence establishing the transaction nature and turnover computation under the ICAI Guidance Note. Where the record does not show whether transactions were futures and options or delivery-based, the tax-audit requirement and consequential penalty require factual verification by the Assessing Officer after the taxpayer provides supporting particulars.
Penalty immunity under the Direct Tax Vivad Se Vishwas Scheme does not extend to an independent penalty for failure to obtain a statutory tax audit merely because related quantum additions were settled. The penalty issue remains separately examinable. For futures and options transactions, tax-audit applicability depends on evidence establishing the transaction nature and turnover computation under the ICAI Guidance Note. Where the record does not show whether transactions were futures and options or delivery-based, the tax-audit requirement and consequential penalty require factual verification by the Assessing Officer after the taxpayer provides supporting particulars.
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