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 78 of FA - there was a confusion at the field level for proper classification of activity undertaken by the appellant as to whether it is under ‘Business Auxiliary Service’ or under ‘Business Support Service’ and there have been multiplicity of interpretation - appellant had also deposited the entire amount of ST demanded under the SCN with interest before issuance of SCN - imposition of penalty u/s 78 is not warranted
Penalty u/s 78 of FA - there was a confusion at the field level for proper classification of activity undertaken by the appellant as to whether it is under ‘Business Auxiliary Service’ or under ‘Business Support Service’ and there have been multiplicity of interpretation - appellant had also deposited the entire amount of ST demanded under the SCN with interest before issuance of SCN - imposition of penalty u/s 78 is not warranted
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