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) - wrongful claim of lower LTCG - Disallowance u/s 94(7) - Dividend Striping - proof of bonafied mistake - ITAT deleted the penalty - Since the assessee had voluminous transactions, it committed an error while posting the relevant dividend entry, which was covered by one voucher since it was received on the same security. - Tribunal has observed that it was a reasonable human error - The assessee has proven that it was a bonafide mistake and no substantial question of law would arise - Appeal of the revenue dismissed - HC
Penalty u/s 271(1)(c) - wrongful claim of lower LTCG - Disallowance u/s 94(7) - Dividend Striping - proof of bonafied mistake - ITAT deleted the penalty - Since the assessee had voluminous transactions, it committed an error while posting the relevant dividend entry, which was covered by one voucher since it was received on the same security. - Tribunal has observed that it was a reasonable human error - The assessee has proven that it was a bonafide mistake and no substantial question of law would arise - Appeal of the revenue dismissed - HC
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