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 u/s 271(1)(c) - wrong claim of set off loss - explanation was not found false - no iota of evidence of concealment of any fact relating to particulars of income or furnishing of inaccurate particulars of income - Merely because the assessee had claimed the expenditure, which was not accepted or was not acceptable to the revenue, that by itself would not, attract the penalty u/s 271(1)(c)
Penalty u/s 271(1)(c) - wrong claim of set off loss - explanation was not found false - no iota of evidence of concealment of any fact relating to particulars of income or furnishing of inaccurate particulars of income - Merely because the assessee had claimed the expenditure, which was not accepted or was not acceptable to the revenue, that by itself would not, attract the penalty u/s 271(1)(c)
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