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 proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
Penalty proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
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