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 proceedings u/s. 221(1) - default as per Section 220 - the AR of the assessee could not explain fund availability position on the due date of payment of advance tax as well as on the date of self-assessment tax i.e. date of filing of return. We also observe form the order of the authorities below, the assessment was completed u/s. 144 by rejecting the books of accounts of the assessee which clearly shows that the intention of the assessee was not in favour of the revenue for the payment of tax. It clearly shows that the assessee was not paying the taxes within the stipulated time. - Levy of penlty confirmed - AT
Penalty proceedings u/s. 221(1) - default as per Section 220 - the AR of the assessee could not explain fund availability position on the due date of payment of advance tax as well as on the date of self-assessment tax i.e. date of filing of return. We also observe form the order of the authorities below, the assessment was completed u/s. 144 by rejecting the books of accounts of the assessee which clearly shows that the intention of the assessee was not in favour of the revenue for the payment of tax. It clearly shows that the assessee was not paying the taxes within the stipulated time. - Levy of penlty confirmed - AT
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