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...
HC considered a case involving offences u/s 276 C (2) r/w sec 278 B of Criminal Procedure for Economic Offences. Petitioners filed returns without paying tax, attributing it to auditors' mistake. They paid the tax upon realization. Citing M/s. Bejan Singh Eye Hospital Pvt. Ltd, HC held a positive act is needed to establish guilt u/s 276 C (2). Since petitioners paid tax with interest upon notice, showing no intent to evade tax, proceedings were quashed. Criminal Petition allowed, proceedings against petitioners quashed by HC.
HC considered a case involving offences u/s 276 C (2) r/w sec 278 B of Criminal Procedure for Economic Offences. Petitioners filed returns without paying tax, attributing it to auditors' mistake. They paid the tax upon realization. Citing M/s. Bejan Singh Eye Hospital Pvt. Ltd, HC held a positive act is needed to establish guilt u/s 276 C (2). Since petitioners paid tax with interest upon notice, showing no intent to evade tax, proceedings were quashed. Criminal Petition allowed, proceedings against petitioners quashed by HC.
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