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...
Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.
Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.
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