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...
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
Penalty u/s 271(1)(c) was imposed on the assessee for not filing the return of income (ROI), despite having a bona fide belief that the income was non-taxable and tax deducted at source (TDS) was deducted on the income. The assessee, a non-profit welfare fund, filed the return and paid the tax in full after receiving a notice u/s 148, before receiving the recorded reasons. The Assessing Officer accepted the return and tax paid, with no findings of concealment of income. Relying on relevant judicial precedents, the Tribunal held that the levy of penalty was unjustified and quashed the penalty u/s 271(1)(c), allowing the assessee's appeal.
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