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) - Period of limitation - denial of deduction u/s 11 - As the petitioner was well aware of the fact that this is the case of filling of inaccurate particulars in the returns and the petitioner has also replied to the same in the notices issued to the petitioner. The petitioner had earlier filed writ petition long after the notices were issued, after the assessment orders were passed by the Assessing Officer. It is only by way of an afterthought the petitioner had challenged the notices. - No relief - HC
Penalty u/s 271(1)(c) - Period of limitation - denial of deduction u/s 11 - As the petitioner was well aware of the fact that this is the case of filling of inaccurate particulars in the returns and the petitioner has also replied to the same in the notices issued to the petitioner. The petitioner had earlier filed writ petition long after the notices were issued, after the assessment orders were passed by the Assessing Officer. It is only by way of an afterthought the petitioner had challenged the notices. - No relief - HC
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