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 held that penalty proceedings u/s 271AAB initiated in order u/s 143(3) became time-barred on 30.9.2017 as no substantive order was passed within statutory limitation period under section 275(1)(a). The Tribunal found the penalty notice defective for failing to specify precise grounds of concealment. Consequently, the penalty order levied on Rs. 1 crore addition was deleted. The assessee's appeal was allowed, effectively quashing the penalty proceedings due to procedural irregularities and limitation constraints in initiating and concluding penalty action.
ITAT held that penalty proceedings u/s 271AAB initiated in order u/s 143(3) became time-barred on 30.9.2017 as no substantive order was passed within statutory limitation period under section 275(1)(a). The Tribunal found the penalty notice defective for failing to specify precise grounds of concealment. Consequently, the penalty order levied on Rs. 1 crore addition was deleted. The assessee's appeal was allowed, effectively quashing the penalty proceedings due to procedural irregularities and limitation constraints in initiating and concluding penalty action.
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