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) - Explanation is bonafide is, we find, supported by the fact that during assessment proceedings the assessee, realizing his mistake even before detection by the Revenue, returned the same to tax. - The assessee having disclosed all particulars of his income from sale of agricultural land, having furnished a bonafide explanation for not returning the same to tax and having surrendered the said income suo moto before detection by the Revenue, we agree with the Ld.CIT(A) that the assessee cannot be said to have furnished inaccurate particulars of income so as to levy penalty u/s 271(1)(c) - AT
Penalty u/s 271(1)(c) - Explanation is bonafide is, we find, supported by the fact that during assessment proceedings the assessee, realizing his mistake even before detection by the Revenue, returned the same to tax. - The assessee having disclosed all particulars of his income from sale of agricultural land, having furnished a bonafide explanation for not returning the same to tax and having surrendered the said income suo moto before detection by the Revenue, we agree with the Ld.CIT(A) that the assessee cannot be said to have furnished inaccurate particulars of income so as to levy penalty u/s 271(1)(c) - AT
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