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 - goods were unloaded at a place that was not registered in the registration certificate - unloading goods at a location not specified in the e-way bill - The petitioner argues that the unloading occurred at their own registered godown, with no intent to evade tax. The court underscores the importance of establishing mens rea for penalty imposition, citing precedents. It distinguishes minor errors from major lapses and concludes that the minor typographical error in the e-way bill, coupled with the absence of intent to evade tax, renders the penalty unwarranted.
Levy of penalty - goods were unloaded at a place that was not registered in the registration certificate - unloading goods at a location not specified in the e-way bill - The petitioner argues that the unloading occurred at their own registered godown, with no intent to evade tax. The court underscores the importance of establishing mens rea for penalty imposition, citing precedents. It distinguishes minor errors from major lapses and concludes that the minor typographical error in the e-way bill, coupled with the absence of intent to evade tax, renders the penalty unwarranted.
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