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) - non compliance to statutory notice u/s 143(2) - there was irregularity in disposing of the objection raised by the assessee against re-opening u/s 147 r.w.s. 148 of the Act which was after four months. Therefore there is irregularity on the part of AO also, which we have observed with the help of sequence of events narrated above, therefore, we note that there is sufficient compliance on the part of assessee to response such notices. - No penalty - AT
Penalty u/s 271(1)(b) - non compliance to statutory notice u/s 143(2) - there was irregularity in disposing of the objection raised by the assessee against re-opening u/s 147 r.w.s. 148 of the Act which was after four months. Therefore there is irregularity on the part of AO also, which we have observed with the help of sequence of events narrated above, therefore, we note that there is sufficient compliance on the part of assessee to response such notices. - No penalty - AT
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