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 u/s 271(1)(c) - Having capitalized the amount of foreign exchange fluctuation in the relevant block of assets reveals its clear intent of treating it as capital expense. Not adding it back while computing the income for the year can be safely beleived to be mistakenly done unless otherwise proved. - We agree with the assessee that it was mistake on his part for not having added the amount to his income. There is, therefore we hold no case for levy of penalty u/s 271(1)(C) of the Act - AT
Penalty u/s 271(1)(c) - Having capitalized the amount of foreign exchange fluctuation in the relevant block of assets reveals its clear intent of treating it as capital expense. Not adding it back while computing the income for the year can be safely beleived to be mistakenly done unless otherwise proved. - We agree with the assessee that it was mistake on his part for not having added the amount to his income. There is, therefore we hold no case for levy of penalty u/s 271(1)(C) of the Act - AT
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