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...
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
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