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...
Levy of penalty - period of limitation for raising demand - the Tribunal has to first judge as to whether the case of the assessee is covered by proviso below sub-section (1) of Section 73 of the Finance Act, 1994. After recording the findings on the aspects so covered by the proviso, the question of limitation as provided under sub-section (1) of Section 73 of the Finance Act will have to be decided.
Levy of penalty - period of limitation for raising demand - the Tribunal has to first judge as to whether the case of the assessee is covered by proviso below sub-section (1) of Section 73 of the Finance Act, 1994. After recording the findings on the aspects so covered by the proviso, the question of limitation as provided under sub-section (1) of Section 73 of the Finance Act will have to be decided.
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