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 u/s.271(1)(c) - defective notice - it would be too technical and pedantic to take the view that because in the printed notice the inapplicable portion was not struck off, the order of penalty should be set aside even though in the assessment order it was clearly mentioned that penalty proceedings u/s 271(1)(c) of the Act had been initiated separately for furnishing inaccurate particulars of income. - However penalty deleted since the assessee had declared the full facts.
Levy of penalty u/s.271(1)(c) - defective notice - it would be too technical and pedantic to take the view that because in the printed notice the inapplicable portion was not struck off, the order of penalty should be set aside even though in the assessment order it was clearly mentioned that penalty proceedings u/s 271(1)(c) of the Act had been initiated separately for furnishing inaccurate particulars of income. - However penalty deleted since the assessee had declared the full facts.
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