Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Penalty u/s 271B - late filing of Tax Audit Report in Form 3CA - The record shows the same to have been obtained on 26.2.2018. The question of explaining the delay by the assessee would arise only where it is furnished with a delay. - No explanation, much less proving the reasonable cause for the delay, which in fact is a continuing one. - Levy of penalty confirmed - AT
Penalty u/s 271B - late filing of Tax Audit Report in Form 3CA - The record shows the same to have been obtained on 26.2.2018. The question of explaining the delay by the assessee would arise only where it is furnished with a delay. - No explanation, much less proving the reasonable cause for the delay, which in fact is a continuing one. - Levy of penalty confirmed - AT
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