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 271C - non-deduction of tax at source from the payment of harvesting charges paid to contractors - We are aware that ignorance of law is not an excuse but at the same time, it is not practical that every taxpayer should always be aware about the latest development of fiscal laws; which are ever and fast changing. We find that, the issue at hand was highly debatable at relevant point of time and assessee was prevented by a reasonable cause for not complying with the provisions - the appellant assessee is entitled to relief from 271C penalty by virtue of provisions of section 273B - AT
Penalty u/s 271C - non-deduction of tax at source from the payment of harvesting charges paid to contractors - We are aware that ignorance of law is not an excuse but at the same time, it is not practical that every taxpayer should always be aware about the latest development of fiscal laws; which are ever and fast changing. We find that, the issue at hand was highly debatable at relevant point of time and assessee was prevented by a reasonable cause for not complying with the provisions - the appellant assessee is entitled to relief from 271C penalty by virtue of provisions of section 273B - AT
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