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 270A - AO has disallowed the assessee’s claim of deduction u/s 24 and Chapter-VIA deduction as false claims - The appellant contested the penalty on various grounds, including lack of specificity in the penalty notice and attributing the underreporting of income to the actions of their tax consultant. Upon examination, the Appellate Tribunal found that the penalty was incorrectly imposed under section 270A(9)(e) for failure to record receipts in the books of accounts, despite the disallowance of deductions being the primary issue. Therefore, the Tribunal directed the Assessing Officer to delete the penalty.
Penalty u/s 270A - AO has disallowed the assessee’s claim of deduction u/s 24 and Chapter-VIA deduction as false claims - The appellant contested the penalty on various grounds, including lack of specificity in the penalty notice and attributing the underreporting of income to the actions of their tax consultant. Upon examination, the Appellate Tribunal found that the penalty was incorrectly imposed under section 270A(9)(e) for failure to record receipts in the books of accounts, despite the disallowance of deductions being the primary issue. Therefore, the Tribunal directed the Assessing Officer to delete the penalty.
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