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 271B - non-compliance of the provisions of sec. 44AB - delay in filing the tax audit report - The reasons are definitely such that they were beyond the control of the assessee and since the Income-tax Act is a welfare legislation the practical difficulties of the tax payers assessee and the bonafide nature has to be considered. - the assessee had even submitted the Doctor's Certificate under whose treatment the accountant was admitted in the hospital. The ld. CIT(A) should have considered all these facts in its proper perspective. - No penalty - AT
Penalty u/s 271B - non-compliance of the provisions of sec. 44AB - delay in filing the tax audit report - The reasons are definitely such that they were beyond the control of the assessee and since the Income-tax Act is a welfare legislation the practical difficulties of the tax payers assessee and the bonafide nature has to be considered. - the assessee had even submitted the Doctor's Certificate under whose treatment the accountant was admitted in the hospital. The ld. CIT(A) should have considered all these facts in its proper perspective. - No penalty - AT
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