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...
Recording of satisfaction in the assessment order is a mandatory pre-condition for initiating penalty under section 271D where the alleged violation concerns section 269SS. The Tribunal held that the additional legal ground could be examined on the existing record because it went to the root of the penalty validity. As the assessment order accepted the assessee's explanation for the cash deposits and did not record any satisfaction for penalty initiation, the penalty proceedings could not be sustained. The penalty order was quashed and the assessee's appeal was allowed.
Recording of satisfaction in the assessment order is a mandatory pre-condition for initiating penalty under section 271D where the alleged violation concerns section 269SS. The Tribunal held that the additional legal ground could be examined on the existing record because it went to the root of the penalty validity. As the assessment order accepted the assessee's explanation for the cash deposits and did not record any satisfaction for penalty initiation, the penalty proceedings could not be sustained. The penalty order was quashed and the assessee's appeal was allowed.
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