Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Penalty u/s 271B - Delay in filing the tax audit report - delay occurred due to the Accountant leaving the job abruptly and it took time for the new Accountant to finalize the accounts - For other years, the assessee was regular in filing the TAR - this is the only year where there is a delay in getting the books of accounts audited u/s 44AB - In the case on hand the tax audit report was filed on 08.03.2018, the return was field on 09.03.2018 and the assessment was completed on 30.12.2019 on which date the tax audit report was very much before the Assessing Officer. Further the assessment was completed accepting the loss returned by the assessee. - No penalty - AT
Penalty u/s 271B - Delay in filing the tax audit report - delay occurred due to the Accountant leaving the job abruptly and it took time for the new Accountant to finalize the accounts - For other years, the assessee was regular in filing the TAR - this is the only year where there is a delay in getting the books of accounts audited u/s 44AB - In the case on hand the tax audit report was filed on 08.03.2018, the return was field on 09.03.2018 and the assessment was completed on 30.12.2019 on which date the tax audit report was very much before the Assessing Officer. Further the assessment was completed accepting the loss returned by the assessee. - No penalty - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
