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 u/s 271C - Whether appellant is entitled to immunity from penalty as the appellant has opted for VSVS in respect of order u/s 201(1)? - Since the dispute is related to the quantum of 201(1) proceedings the same is already settled and therefore, penalty cannot be imposed subsequently under Section 271C of the Act. - AT
Levy of penalty u/s 271C - Whether appellant is entitled to immunity from penalty as the appellant has opted for VSVS in respect of order u/s 201(1)? - Since the dispute is related to the quantum of 201(1) proceedings the same is already settled and therefore, penalty cannot be imposed subsequently under Section 271C of the Act. - AT
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