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)(b) - failure to sign on the so called "Consent Letter" which is not an authorized form notified by the Government - In the context of section 273B of the Act, the expression "reasonable cause" has been explained to mean a cause which prevents a man of ordinary prudence and average intelligence, acting under normal circumstances, without negligence or inaction or want of bona fide. - Levy of penalty deleted - AT
Penalty u/s 271(1)(b) - failure to sign on the so called "Consent Letter" which is not an authorized form notified by the Government - In the context of section 273B of the Act, the expression "reasonable cause" has been explained to mean a cause which prevents a man of ordinary prudence and average intelligence, acting under normal circumstances, without negligence or inaction or want of bona fide. - Levy of penalty deleted - AT
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