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 for violation of section 129 and Rule 138 - Failure to update the E-way bill on change of vehicle after breakdown - The imposition of penalties for mere technical errors in tax law, without evidence of intent to evade tax, is not sustainable. The court emphasized that penalties should only be imposed when there's a deliberate intent to evade taxes, differentiating between inadvertent technical errors and purposeful attempts to circumvent tax obligations. - HC
Levy of penalty for violation of section 129 and Rule 138 - Failure to update the E-way bill on change of vehicle after breakdown - The imposition of penalties for mere technical errors in tax law, without evidence of intent to evade tax, is not sustainable. The court emphasized that penalties should only be imposed when there's a deliberate intent to evade taxes, differentiating between inadvertent technical errors and purposeful attempts to circumvent tax obligations. - HC
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