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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Penalty u/s 270A and 271AAB - Defective notice u/s 274 - under reporting of income - search and seizure operation - The Tribunal found that the penalty notices under sections 270A and 271AAB were not in compliance with the legal requirements, as they failed to specify the exact limb under which the penalties were being levied (misreporting or underreporting of income). This lack of specificity was deemed to render the notices vague and legally insufficient to form the basis for penalty proceedings. - The Tribunal underscored that penalty proceedings are independent of assessment proceedings and must stand on their own merits. - The ITAT allowed the appeals filed by the firm, deleting the penalties
Penalty u/s 270A and 271AAB - Defective notice u/s 274 - under reporting of income - search and seizure operation - The Tribunal found that the penalty notices under sections 270A and 271AAB were not in compliance with the legal requirements, as they failed to specify the exact limb under which the penalties were being levied (misreporting or underreporting of income). This lack of specificity was deemed to render the notices vague and legally insufficient to form the basis for penalty proceedings. - The Tribunal underscored that penalty proceedings are independent of assessment proceedings and must stand on their own merits. - The ITAT allowed the appeals filed by the firm, deleting the penalties
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
