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...
ITAT adjudicated a tax dispute regarding penalty u/s 271(1)(c), finding no justification for penalty imposition. The tribunal determined that returned income matched assessed income, and no substantive evidence of income concealment existed. The show cause notice lacked specific allegations of tax evasion or inaccurate income particulars. Given the absence of procedural fairness and no demonstrable intent to evade tax, the tribunal deleted the 100% penalty. The decision hinged on procedural defects and lack of clear evidence of deliberate tax non-compliance, ultimately ruling in favor of the assessee based on principles of natural justice and procedural propriety.
ITAT adjudicated a tax dispute regarding penalty u/s 271(1)(c), finding no justification for penalty imposition. The tribunal determined that returned income matched assessed income, and no substantive evidence of income concealment existed. The show cause notice lacked specific allegations of tax evasion or inaccurate income particulars. Given the absence of procedural fairness and no demonstrable intent to evade tax, the tribunal deleted the 100% penalty. The decision hinged on procedural defects and lack of clear evidence of deliberate tax non-compliance, ultimately ruling in favor of the assessee based on principles of natural justice and procedural propriety.
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