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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The Appellate Tribunal considered a case involving penalty u/s 271(1)(c) for furnishing inaccurate particulars of income. The Assessee did not disclose non-eligibility of brought forward losses in the return. The Assessee voluntarily paid additional taxes before assessment proceedings. The Tribunal held that the Assessee's actions were not deliberate inaccuracies. The Tribunal found no concealment or inaccurate particulars at the time of filing the return. The Tribunal dismissed the Revenue's claim that the Assessee could have claimed a refund if not selected for scrutiny. The Tribunal emphasized that the Assessee's explanation was bona fide and that the penalty under u/s 271(1)(c) was not justified. The Tribunal ruled in favor of the Assessee, stating that the conditions for imposing the penalty were not met.
The Appellate Tribunal considered a case involving penalty u/s 271(1)(c) for furnishing inaccurate particulars of income. The Assessee did not disclose non-eligibility of brought forward losses in the return. The Assessee voluntarily paid additional taxes before assessment proceedings. The Tribunal held that the Assessee's actions were not deliberate inaccuracies. The Tribunal found no concealment or inaccurate particulars at the time of filing the return. The Tribunal dismissed the Revenue's claim that the Assessee could have claimed a refund if not selected for scrutiny. The Tribunal emphasized that the Assessee's explanation was bona fide and that the penalty under u/s 271(1)(c) was not justified. The Tribunal ruled in favor of the Assessee, stating that the conditions for imposing the penalty were not met.
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