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...
Rejection of a compounding application filed beyond the prescribed time limit as per the CBDT circular. The High Court held that the CBDT cannot issue a circular contrary to the object of the provisions, and fixing a time limit for filing a compounding application is not permissible u/s 279(2) of the Income Tax Act. The Court ruled that once an offence is compoundable by law, its compoundability cannot be restricted by imposing a time limit. The impugned order was set aside, and the matter was remanded to the respondent to consider the compounding application on record, as the petitioner was not a habitual offender.
Rejection of a compounding application filed beyond the prescribed time limit as per the CBDT circular. The High Court held that the CBDT cannot issue a circular contrary to the object of the provisions, and fixing a time limit for filing a compounding application is not permissible u/s 279(2) of the Income Tax Act. The Court ruled that once an offence is compoundable by law, its compoundability cannot be restricted by imposing a time limit. The impugned order was set aside, and the matter was remanded to the respondent to consider the compounding application on record, as the petitioner was not a habitual offender.
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