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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Levy of penalty u/s 271(1)(b) - non appearance before the Assessing Officer - AO kept an issuing notices on the wrong address even when the first notice was not served due to wrong address. All these series of facts shows that there was a mis-communication at the end of the AO about the address and also not mentioning the husband’s name of the assessee which resulted in non serving of the notice since she resided in village - no justification in the action of the AO in initiating and levying penalty u/s 271(1)(b). - AT
Levy of penalty u/s 271(1)(b) - non appearance before the Assessing Officer - AO kept an issuing notices on the wrong address even when the first notice was not served due to wrong address. All these series of facts shows that there was a mis-communication at the end of the AO about the address and also not mentioning the husband’s name of the assessee which resulted in non serving of the notice since she resided in village - no justification in the action of the AO in initiating and levying penalty u/s 271(1)(b). - AT
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