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...
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
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