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 levied u/s 271D and 271E - accepting deposits by way of journal entries - assessee had accepted/paid loans in contravention of provision of section 269SS/269T - the Hon’ble Bombay High Court has specifically observed that irrespective whether the transaction was bonafide or non-bonafide, repayment of loan by debiting amount through journal entries was in the nature of contravention of section 269T. - Levy of penalty confirmed - AT
Penalty levied u/s 271D and 271E - accepting deposits by way of journal entries - assessee had accepted/paid loans in contravention of provision of section 269SS/269T - the Hon’ble Bombay High Court has specifically observed that irrespective whether the transaction was bonafide or non-bonafide, repayment of loan by debiting amount through journal entries was in the nature of contravention of section 269T. - Levy of penalty confirmed - AT
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