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. 272A(1)(d) - non compliance to notice u/s. 142(1) due to covid pandemic - addition u/s. 68 - As it is observed that when there is a reasonable cause for the said failure, the penalty imposed u/s. 272A sub section (1) of the Act is protected as per the provision of section 272B where the penalty shall not be imposed when the assessee has substantiated reasonable cause for such failure. - AT
Penalty u/s. 272A(1)(d) - non compliance to notice u/s. 142(1) due to covid pandemic - addition u/s. 68 - As it is observed that when there is a reasonable cause for the said failure, the penalty imposed u/s. 272A sub section (1) of the Act is protected as per the provision of section 272B where the penalty shall not be imposed when the assessee has substantiated reasonable cause for such failure. - AT
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