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...
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
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