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/s 271(1)(c) - bogus claim u/s 80C - The Tribunal found that there was a discrepancy in the application of penalties by the lower authorities. - While the Assessing Officer concluded it as a case of furnishing inaccurate particulars of income, the subsequent discussion by the National Faceless Appeal Centre deemed it as concealment of taxable income. - Citing a relevant high court decision, the Tribunal deemed this deviation unsustainable in law. - Consequently, the penalty was deemed inappropriate and was deleted.
Penalty u/s 271(1)(c) - bogus claim u/s 80C - The Tribunal found that there was a discrepancy in the application of penalties by the lower authorities. - While the Assessing Officer concluded it as a case of furnishing inaccurate particulars of income, the subsequent discussion by the National Faceless Appeal Centre deemed it as concealment of taxable income. - Citing a relevant high court decision, the Tribunal deemed this deviation unsustainable in law. - Consequently, the penalty was deemed inappropriate and was deleted.
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