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 proceedings u/s 271B - requirement of getting tax audit u/s 44AB - Determination of turnover - non-delivery based trading of shares and securities - in such case the turnover has to be determined on the basis of the net of sales and purchase of shares - Further the default committed by the assessee is of technical nature and the AO was not handicapped for want of tax audit report while making assessment under appeal. - there is no requirement for getting the accounts audited u/s 44AB - No penalty - AT
Penalty proceedings u/s 271B - requirement of getting tax audit u/s 44AB - Determination of turnover - non-delivery based trading of shares and securities - in such case the turnover has to be determined on the basis of the net of sales and purchase of shares - Further the default committed by the assessee is of technical nature and the AO was not handicapped for want of tax audit report while making assessment under appeal. - there is no requirement for getting the accounts audited u/s 44AB - No penalty - AT
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