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...
The ITAT deleted penalty for alleged unexplained cash receipts, holding that the assessee's explanation that estimated income was offered and tax was paid to buy peace and avoid prolonged litigation was plausible on the facts. The Tribunal also noted that, on a similar explanation, the AO had already dropped penalty proceedings for under-reporting of income. On an overall review of the digital material and surrounding record, it found the evidence insufficient to justify sustaining the penalty for alleged cash transactions.
The ITAT deleted penalty for alleged unexplained cash receipts, holding that the assessee's explanation that estimated income was offered and tax was paid to buy peace and avoid prolonged litigation was plausible on the facts. The Tribunal also noted that, on a similar explanation, the AO had already dropped penalty proceedings for under-reporting of income. On an overall review of the digital material and surrounding record, it found the evidence insufficient to justify sustaining the penalty for alleged cash transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
