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...
The Appellate Tribunal held that the penalty imposed u/s 272A(1)(d) for non-compliance with notices u/s 142(1) was not legally valid. The Assessing Officer failed to prove actual service of notices u/s 142(1), and willful default by the assessee could not be established. The Tribunal observed that separate penalty proceedings should have been initiated for each failure, instead of a consolidated penalty order. In the absence of proof of service, the penalty was deleted, and the assessee's appeal was allowed.
The Appellate Tribunal held that the penalty imposed u/s 272A(1)(d) for non-compliance with notices u/s 142(1) was not legally valid. The Assessing Officer failed to prove actual service of notices u/s 142(1), and willful default by the assessee could not be established. The Tribunal observed that separate penalty proceedings should have been initiated for each failure, instead of a consolidated penalty order. In the absence of proof of service, the penalty was deleted, and the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
