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 u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
Penalty u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
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