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 u/s 271(1)(c) - denial of claim of embezzlement loss - The fact that the cheque does not figure in the bank account of other party does not by itself prove the explanation of the assessee as wrong, as long as cheque stands reflected as issued in the bank statement of the assessee, which was not proved to be false by the Revenue. - No penalty - AT
Penalty u/s 271(1)(c) - denial of claim of embezzlement loss - The fact that the cheque does not figure in the bank account of other party does not by itself prove the explanation of the assessee as wrong, as long as cheque stands reflected as issued in the bank statement of the assessee, which was not proved to be false by the Revenue. - No penalty - AT
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