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 u/ss 271D and 271E was challenged - default u/ss 269SS and 269T - assessee received and repaid cash loans from directors and related concerns - assessee contended cash was received to meet urgent expenses at project site when funds were unavailable - argument that cash loans from directors were exempt from sections 269SS and 269T rejected as no such exception exists in statute - limitation argument rejected as proceedings completed within statutory limit - delay due to COVID-19 pandemic excluded - penalty levy inappropriate given assessee's business requiring frequent expenditure at distant project site and possibility of cash loans from directors due to exigency - appeals allowed by deleting penalties.
Levy of penalty u/ss 271D and 271E was challenged - default u/ss 269SS and 269T - assessee received and repaid cash loans from directors and related concerns - assessee contended cash was received to meet urgent expenses at project site when funds were unavailable - argument that cash loans from directors were exempt from sections 269SS and 269T rejected as no such exception exists in statute - limitation argument rejected as proceedings completed within statutory limit - delay due to COVID-19 pandemic excluded - penalty levy inappropriate given assessee's business requiring frequent expenditure at distant project site and possibility of cash loans from directors due to exigency - appeals allowed by deleting penalties.
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