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 u/s. 271(1)(c) - The appellant contended that the addition made by the Assessing Officer was based solely on estimations, making it ineligible for penalty imposition. The ITAT upheld this argument, citing legal precedents to support its decision. Additionally, the court noted the defective nature of the penalty notice issued by the Assessing Officer, further bolstering the appellant's case. - Consequently, the Tribunal set aside the impugned order and allowed the appellant's appeal, directing the deletion of the penalty.
Levy of penalty u/s. 271(1)(c) - The appellant contended that the addition made by the Assessing Officer was based solely on estimations, making it ineligible for penalty imposition. The ITAT upheld this argument, citing legal precedents to support its decision. Additionally, the court noted the defective nature of the penalty notice issued by the Assessing Officer, further bolstering the appellant's case. - Consequently, the Tribunal set aside the impugned order and allowed the appellant's appeal, directing the deletion of the penalty.
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