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) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
Penalty u/s 271 (1)(c) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
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