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 Appellate Tribunal upheld the finding that the appellant contravened Section 3(a) of FEMA in relation to unauthorised foreign exchange dealing, relying on corroborative statements, recovery of US $ 10,000 from the appellant's personal custody, and the absence of a credible explanation for possession of the currency. The plea based on educational background was rejected because the persons involved had prior money-changing experience and were expected to know the legal requirements. Liability for penalty was therefore sustained, but the Tribunal reduced the quantum of penalty in view of the facts and circumstances and directed adjustment of the pre-deposit against the reduced amount.
The Appellate Tribunal upheld the finding that the appellant contravened Section 3(a) of FEMA in relation to unauthorised foreign exchange dealing, relying on corroborative statements, recovery of US $ 10,000 from the appellant's personal custody, and the absence of a credible explanation for possession of the currency. The plea based on educational background was rejected because the persons involved had prior money-changing experience and were expected to know the legal requirements. Liability for penalty was therefore sustained, but the Tribunal reduced the quantum of penalty in view of the facts and circumstances and directed adjustment of the pre-deposit against the reduced amount.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
