Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Penalty u/s 271(1)(c) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
Penalty u/s 271(1)(c) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
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