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 - mis-declaration of description of imported goods - Having found that the appellant had no intention, the Commissioner (Appeals) has still proceed to confirmed a reduced penalty under section 114AA upon the appellant - It is found that this cannot be sustained because once the intention is lacking, no penalty can be imposed upon the appellant under section 114AA. - AT
Levy of penalty - mis-declaration of description of imported goods - Having found that the appellant had no intention, the Commissioner (Appeals) has still proceed to confirmed a reduced penalty under section 114AA upon the appellant - It is found that this cannot be sustained because once the intention is lacking, no penalty can be imposed upon the appellant under section 114AA. - AT
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