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) - assessee had wrongly shown the rental income as 'business income' - Even the pertinent fact on the file is that in the immediate preceding assessment year, the assessee had offered the same income as income from business and which was accepted by the AO under scrutiny assessment proceedings. Under the circumstances for the assessment year under consideration, the assessee can safely be said to be having bonafide belief for offering the same under the same head i.e. 'income from business or profession'. - No penalty - AT
Penalty u/s. 271(1)(c) - assessee had wrongly shown the rental income as 'business income' - Even the pertinent fact on the file is that in the immediate preceding assessment year, the assessee had offered the same income as income from business and which was accepted by the AO under scrutiny assessment proceedings. Under the circumstances for the assessment year under consideration, the assessee can safely be said to be having bonafide belief for offering the same under the same head i.e. 'income from business or profession'. - No penalty - AT
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