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. 271A(2)(g) - default in compliance of TDS provision - financial crisis - The assessee has demonstrated from the material placed on record that because of financial crisis there was delay in depositing TDS, therefore, TDS return filed late which resulted in issuing TDS certificate late - neither the AO nor the Ld. CIT(A) has controverted nor disprove the contention of the assessee that there was financial crisis, therefore, we consider that the case of the assessee is covered by the provision of Section 273B of the Act - No penalty - AT
Levy of penalty u/s. 271A(2)(g) - default in compliance of TDS provision - financial crisis - The assessee has demonstrated from the material placed on record that because of financial crisis there was delay in depositing TDS, therefore, TDS return filed late which resulted in issuing TDS certificate late - neither the AO nor the Ld. CIT(A) has controverted nor disprove the contention of the assessee that there was financial crisis, therefore, we consider that the case of the assessee is covered by the provision of Section 273B of the Act - No penalty - AT
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