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...
HC dismissed the writ petition challenging a penalty order under Section 271D of the Income Tax Act. The court held that the limitation period for passing the penalty order was extended till 31.03.2022 through Notification No.113/2021, rendering the order dated 19.08.2021 within valid jurisdiction. The petitioner's arguments regarding premature order and awaiting appellate commissioner's decision were rejected. The court granted liberty to the petitioner to file an appeal before the Appellate Commissioner under Section 246A within 30 days of receiving the order's copy, effectively upholding the penalty order's validity.
HC dismissed the writ petition challenging a penalty order under Section 271D of the Income Tax Act. The court held that the limitation period for passing the penalty order was extended till 31.03.2022 through Notification No.113/2021, rendering the order dated 19.08.2021 within valid jurisdiction. The petitioner's arguments regarding premature order and awaiting appellate commissioner's decision were rejected. The court granted liberty to the petitioner to file an appeal before the Appellate Commissioner under Section 246A within 30 days of receiving the order's copy, effectively upholding the penalty order's validity.
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