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...
Penalty levied u/s. 271(1)(c) - Suo-moto declaration of undisclosed assets located outside India under section 59 of the Black Money (Undisclosed Foreign Income and Asset and Imposition of Tax Act, 2015) - assessee paid the tax @ 30% along with equal amount by way of penalty. - Assessing Officer did not apply his mind. The ld. CIT(A) has unreasonably sustained the impugned penalty levied u/s. 271(1)(c) of the Act. - AT
Penalty levied u/s. 271(1)(c) - Suo-moto declaration of undisclosed assets located outside India under section 59 of the Black Money (Undisclosed Foreign Income and Asset and Imposition of Tax Act, 2015) - assessee paid the tax @ 30% along with equal amount by way of penalty. - Assessing Officer did not apply his mind. The ld. CIT(A) has unreasonably sustained the impugned penalty levied u/s. 271(1)(c) of the Act. - AT
Note: It is a system-generated summary and is for quick reference only.