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 notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
Penalty notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
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