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...
Quantum of redemption fine and penalty - misdeclaration of description and value - The redemption fine imposed by the Ld. Commissioner (Appeal) is sufficient in the interest of justice. Further, in the impugned order, the Ld. Commissioner (Appeal) recorded the finding that there is no finding given by the adjudicating authority for imposing the penalty under Section 117 of the Act. In that circumstances, the Ld. Commissioner(Appeal) has rightly dropped the penalty against the respondent. - AT
Quantum of redemption fine and penalty - misdeclaration of description and value - The redemption fine imposed by the Ld. Commissioner (Appeal) is sufficient in the interest of justice. Further, in the impugned order, the Ld. Commissioner (Appeal) recorded the finding that there is no finding given by the adjudicating authority for imposing the penalty under Section 117 of the Act. In that circumstances, the Ld. Commissioner(Appeal) has rightly dropped the penalty against the respondent. - AT
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