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...
Levying penalty u/s. 271(1)(c) - The appellant, a partner in a partnership firm, had disclosed all particulars of income, including remuneration and interest on capitals received from the firm, in the original return filed. Despite the incorrect claim made under section 44AD of the Act, the Tribunal found no evidence of concealment or furnishing inaccurate particulars. Relying on legal precedents and considering the disclosure made by the appellant, the Tribunal concluded that the penalty was unwarranted.
Levying penalty u/s. 271(1)(c) - The appellant, a partner in a partnership firm, had disclosed all particulars of income, including remuneration and interest on capitals received from the firm, in the original return filed. Despite the incorrect claim made under section 44AD of the Act, the Tribunal found no evidence of concealment or furnishing inaccurate particulars. Relying on legal precedents and considering the disclosure made by the appellant, the Tribunal concluded that the penalty was unwarranted.
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