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...
Validity of Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - The tribunal, following the Judgement of Supreme Court, confirmed the order of CIT(A) for deleting the penalty on account of no satisfaction recorded by the Ld. AO in the reassessment order u/s 147 r.w.s. 144 r.w.s. 144B.
Validity of Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - The tribunal, following the Judgement of Supreme Court, confirmed the order of CIT(A) for deleting the penalty on account of no satisfaction recorded by the Ld. AO in the reassessment order u/s 147 r.w.s. 144 r.w.s. 144B.
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