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 proceedings u/s. 271(1)(b) - non-compliance with the 3 notices u/s. 142(1) - Delay in late response as per date mentioned in notice - The Tribunal found merit in the assessee's explanations for the delays, considering factors such as difficulties in data retrieval, operational challenges, and lack of technical expertise. It observed that the delays were not intentional but were due to genuine constraints faced by the assessee. - The ITAT noted that while there were delays in responding to the notices, the assessee eventually provided all the required details and participated in the assessment proceedings. - The ITAT held that there was reasonable cause for the delays in compliance and that the penalties were unjustified.
Penalty proceedings u/s. 271(1)(b) - non-compliance with the 3 notices u/s. 142(1) - Delay in late response as per date mentioned in notice - The Tribunal found merit in the assessee's explanations for the delays, considering factors such as difficulties in data retrieval, operational challenges, and lack of technical expertise. It observed that the delays were not intentional but were due to genuine constraints faced by the assessee. - The ITAT noted that while there were delays in responding to the notices, the assessee eventually provided all the required details and participated in the assessment proceedings. - The ITAT held that there was reasonable cause for the delays in compliance and that the penalties were unjustified.
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