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 271(1)(c) - A mere bonafide omission on the part of the assessee to account for the interest portion of the refund (which though had duly been reflected in his ‘Capital account’), would though have justified an addition to the said extent, however, a levy of penalty u/s 271(1)(c) merely for the said bonafide mistake would be totally unjustified.
Penalty u/s 271(1)(c) - A mere bonafide omission on the part of the assessee to account for the interest portion of the refund (which though had duly been reflected in his ‘Capital account’), would though have justified an addition to the said extent, however, a levy of penalty u/s 271(1)(c) merely for the said bonafide mistake would be totally unjustified.
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