Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
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