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...
Forensic extraction from a director's mobile phone was treated as admissible without a separate section 138C certificate because the phone was recovered under panchnama and examined in context with the surrounding record. Rule 12 permitted rejection of declared transaction value where reasonable doubt arose from the director's statement and parallel invoices showing higher values, so re-determination of assessable value was upheld. Misdeclaration of value attracted confiscation under section 111(m), and the same undisclosed invoices justified invocation of the extended period under section 28(4). Differential duty and equal penalty under section 114A were sustained, but separate penalties under section 114AA were set aside.
Forensic extraction from a director's mobile phone was treated as admissible without a separate section 138C certificate because the phone was recovered under panchnama and examined in context with the surrounding record. Rule 12 permitted rejection of declared transaction value where reasonable doubt arose from the director's statement and parallel invoices showing higher values, so re-determination of assessable value was upheld. Misdeclaration of value attracted confiscation under section 111(m), and the same undisclosed invoices justified invocation of the extended period under section 28(4). Differential duty and equal penalty under section 114A were sustained, but separate penalties under section 114AA were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
