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)(b) - no compliance to notice u/s 142(1) - The AO levied the penalty for non-compliance of notice dated 13.06.2016, however, there is no reference of such notice for the assessment order, therefore, the order in levying penalty under section 271(1)(b) is invalid. - Furthermore, hen assessee itself offered additional income, which was debited on account of interest on TDS and the same was accepted by AO. And no other issue was identified nor was any other addition made in the assessment order, no penalty should be levied - AT
Penalty u/s.271(1)(b) - no compliance to notice u/s 142(1) - The AO levied the penalty for non-compliance of notice dated 13.06.2016, however, there is no reference of such notice for the assessment order, therefore, the order in levying penalty under section 271(1)(b) is invalid. - Furthermore, hen assessee itself offered additional income, which was debited on account of interest on TDS and the same was accepted by AO. And no other issue was identified nor was any other addition made in the assessment order, no penalty should be levied - AT
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