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 levied u/s 270A - misreporting of income un/s 270A(8) and 270A(9) or not - Assessee filed the ITR after search conducted on third party but before the due date of filing of ITR - Since the return of income was not due as on the date of search carried out on 10.08.2016 and the accounting year was not ended also therefore the books of accounts were not up-dated. Therefore, the assessee's case does not fall under the category of misreporting of income. - No penalty - HC
Penalty levied u/s 270A - misreporting of income un/s 270A(8) and 270A(9) or not - Assessee filed the ITR after search conducted on third party but before the due date of filing of ITR - Since the return of income was not due as on the date of search carried out on 10.08.2016 and the accounting year was not ended also therefore the books of accounts were not up-dated. Therefore, the assessee's case does not fall under the category of misreporting of income. - No penalty - HC
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