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...
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Penalty u/s 271D - assessee is a small trader - household expenses incurred and paid from firm have been entered in cash book debited to assessee's a/c and crediting the A/c of firm M/s Rambilas Shiv Kumar, hence no 'money' passed from firm to the assessee - the transaction between the assessee and firm was current account in nature and was not a loan or deposit and hence there is no violation of section 269SS - no penalty
Penalty u/s 271D - assessee is a small trader - household expenses incurred and paid from firm have been entered in cash book debited to assessee's a/c and crediting the A/c of firm M/s Rambilas Shiv Kumar, hence no 'money' passed from firm to the assessee - the transaction between the assessee and firm was current account in nature and was not a loan or deposit and hence there is no violation of section 269SS - no penalty
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