Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
Reasonable cause under section 273B excused failures to deduct tax from rent paid to a Government-owned company and to collect tax on construction scrap. ITAT accepted the payer's bona fide belief that the Government-owned payee was a Government instrumentality not subject to tax deduction at source, treating that belief as reasonable cause; the rent-related penalty was deleted. ITAT also accepted the bona fide understanding that scrap arising from construction activities, including cutting and moulding materials, was not scrap covered by the tax-collection provisions because construction was not treated as manufacturing. The related tax-collection penalty was likewise deleted.
Reasonable cause under section 273B excused failures to deduct tax from rent paid to a Government-owned company and to collect tax on construction scrap. ITAT accepted the payer's bona fide belief that the Government-owned payee was a Government instrumentality not subject to tax deduction at source, treating that belief as reasonable cause; the rent-related penalty was deleted. ITAT also accepted the bona fide understanding that scrap arising from construction activities, including cutting and moulding materials, was not scrap covered by the tax-collection provisions because construction was not treated as manufacturing. The related tax-collection penalty was likewise deleted.
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