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...
Waiver of interest u/s 234A, 234B and 234C - Interest assessed on account of non-payment of advance tax - prayer for waiver of Interest declined as that late assessee (Husband of the Petitioner) had furnished incorrect particulars in Form 15-H in order to avoid the payment of taxes - The court concluded that (Late) assessee's actions, including filing returns promptly upon receiving notices and depositing tax liabilities, did not constitute voluntary filing without detection. However, it recognized his age and illiteracy as relevant factors constituting unavoidable circumstances. - The court quashed the order of the Chief Commissioner, waived the interest demanded, and set aside subsequent proceedings under Section 140 of the Income Tax Act.
Waiver of interest u/s 234A, 234B and 234C - Interest assessed on account of non-payment of advance tax - prayer for waiver of Interest declined as that late assessee (Husband of the Petitioner) had furnished incorrect particulars in Form 15-H in order to avoid the payment of taxes - The court concluded that (Late) assessee's actions, including filing returns promptly upon receiving notices and depositing tax liabilities, did not constitute voluntary filing without detection. However, it recognized his age and illiteracy as relevant factors constituting unavoidable circumstances. - The court quashed the order of the Chief Commissioner, waived the interest demanded, and set aside subsequent proceedings under Section 140 of the Income Tax Act.
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