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 - Applicability of ration of decision made in the case of co-noticee - in absence of the appeal by revenue against this order the order has acquired finality and Commissioner cannot have passed any order beyond the order passed by his predecessor. In view of this fact, the Commissioner order imposing penalty on Shri JS cannot be sustained and the penalty imposed on Shri SS cannot be in excess of the penalty imposed by this order. - AT
Levy of penalty - Applicability of ration of decision made in the case of co-noticee - in absence of the appeal by revenue against this order the order has acquired finality and Commissioner cannot have passed any order beyond the order passed by his predecessor. In view of this fact, the Commissioner order imposing penalty on Shri JS cannot be sustained and the penalty imposed on Shri SS cannot be in excess of the penalty imposed by this order. - AT
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