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 - Under-reporting of income / Mis-reporting - Interest income from income tax refunds - After reviewing the submissions and case materials, the Tribunal found that the interest income was indeed disclosed by the taxpayer during the quantum assessment and formed part of the computation submitted. Rejecting the Revenue's request for verification, the Tribunal emphasized that all relevant details were already part of the case file. Relying on legal precedent, the Tribunal concluded that there was no justification for the imposed penalty and proceeded to delete it.
Penalty u/s. 270A - Under-reporting of income / Mis-reporting - Interest income from income tax refunds - After reviewing the submissions and case materials, the Tribunal found that the interest income was indeed disclosed by the taxpayer during the quantum assessment and formed part of the computation submitted. Rejecting the Revenue's request for verification, the Tribunal emphasized that all relevant details were already part of the case file. Relying on legal precedent, the Tribunal concluded that there was no justification for the imposed penalty and proceeded to delete it.
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