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...
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
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