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, in a best judgment assessment for gross profit estimation, the assessee's earlier year on identical facts provided the proper benchmark. The ad hoc estimation of income at 2 per cent of turnover was rejected because no distinguishing feature was shown, and income was directed to be computed at 0.40 per cent of gross sales. On the penalty issue, the Tribunal held that once substantial relief was granted in quantum and the basis of estimation was substituted, the foundation for penalty for inaccurate particulars did not survive. The penalty was therefore deleted.
ITAT held that, in a best judgment assessment for gross profit estimation, the assessee's earlier year on identical facts provided the proper benchmark. The ad hoc estimation of income at 2 per cent of turnover was rejected because no distinguishing feature was shown, and income was directed to be computed at 0.40 per cent of gross sales. On the penalty issue, the Tribunal held that once substantial relief was granted in quantum and the basis of estimation was substituted, the foundation for penalty for inaccurate particulars did not survive. The penalty was therefore deleted.
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