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 271AAB(1A)(b) was levied for suo moto disallowance of personal expenses u/s 37 by the assessee in the return filed in response to a notice u/s 153A. The assessee had made the disallowance in the search assessment completed u/s 153A, where no concealment was found. The issue of levying penalty u/s 271AAB in such circumstances is no longer res integra, following the Delhi High Court's decision in Neeraj Jindal. Accordingly, the penalty u/s 271AAB is deleted.
Penalty u/s 271AAB(1A)(b) was levied for suo moto disallowance of personal expenses u/s 37 by the assessee in the return filed in response to a notice u/s 153A. The assessee had made the disallowance in the search assessment completed u/s 153A, where no concealment was found. The issue of levying penalty u/s 271AAB in such circumstances is no longer res integra, following the Delhi High Court's decision in Neeraj Jindal. Accordingly, the penalty u/s 271AAB is deleted.
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