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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...
Levy of Penalty order u/s 129(3) - Neither in the SCN nor in the order u/s 129(3) there was any allegation that non downloading of E-way Bill-02 was done with intention to evade tax - The court noted that there was no allegation of intentional tax evasion in the case of the petitioner, whose goods were detained after completion of the journey. The imposition of the maximum penalty was found unjustifiable, and the court ruled in favor of the petitioner, allowing the writ petition and granting consequential reliefs. - HC
Levy of Penalty order u/s 129(3) - Neither in the SCN nor in the order u/s 129(3) there was any allegation that non downloading of E-way Bill-02 was done with intention to evade tax - The court noted that there was no allegation of intentional tax evasion in the case of the petitioner, whose goods were detained after completion of the journey. The imposition of the maximum penalty was found unjustifiable, and the court ruled in favor of the petitioner, allowing the writ petition and granting consequential reliefs. - HC
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