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 271G - assessee failed to keep and maintain any information as per the provisions of section 92D - The order of authorities below is conspicuous inasmuch as there is no mention as to what document required/ordered for and which were not maintained. The order passed by the authorities below is mechanical without proper application of mind. Hence, on the touchstone of above discussion and precedents we set aside the order of authorities below and direct that the penalty be deleted - AT
Penalty u/s 271G - assessee failed to keep and maintain any information as per the provisions of section 92D - The order of authorities below is conspicuous inasmuch as there is no mention as to what document required/ordered for and which were not maintained. The order passed by the authorities below is mechanical without proper application of mind. Hence, on the touchstone of above discussion and precedents we set aside the order of authorities below and direct that the penalty be deleted - AT
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