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 271D - accepting cash loan of Rs. 2 lakh in aggregate without any reasonable cause in contravention to section 269SS - transactions between father and son, both carrying on their independent business - The Tribunal held that, genuineness of transaction has not been doubted. All the transactions were accounted for by the assessee and his son in their respective books of account. The impugned transaction is reportedly to meet business exigency. - No penalty.
Penalty u/s 271D - accepting cash loan of Rs. 2 lakh in aggregate without any reasonable cause in contravention to section 269SS - transactions between father and son, both carrying on their independent business - The Tribunal held that, genuineness of transaction has not been doubted. All the transactions were accounted for by the assessee and his son in their respective books of account. The impugned transaction is reportedly to meet business exigency. - No penalty.
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