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 271(1) (c) - period of limitation - treatment of lease rent income - in the revised return, assessee claimed the same as income from house property to claim 30% standard deduction - AO treated the income of the assessee as income from business and initiated penalty proceedings - ITAT found that the penalty order was indeed unsustainable as it was passed beyond the prescribed time limit under section 275. Moreover, the ITAT emphasized that the mere rejection of a claim by the Revenue does not automatically warrant penalty imposition unless there is evidence of concealment or furnishing inaccurate particulars.
Penalty u/s 271(1) (c) - period of limitation - treatment of lease rent income - in the revised return, assessee claimed the same as income from house property to claim 30% standard deduction - AO treated the income of the assessee as income from business and initiated penalty proceedings - ITAT found that the penalty order was indeed unsustainable as it was passed beyond the prescribed time limit under section 275. Moreover, the ITAT emphasized that the mere rejection of a claim by the Revenue does not automatically warrant penalty imposition unless there is evidence of concealment or furnishing inaccurate particulars.
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