Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
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