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 ITAT, an Appellate Tribunal, considered the levy of penalty u/s 271(1)(c) for disallowance of prior period expenditure and ad hoc disallowance due to non-filing of relevant documents. The assessee inadvertently claimed a higher share of indexed costs of construction and improvement. Citing the case law RELIANCE PETROPRODUCTS PVT. LTD., it was established that a mere claim, even if rejected by the Assessing Officer, does not warrant penalty. The additional indexed costs of improvement claimed by the assessee were found to be inadvertent and did not result in any benefit. Therefore, the penalty was not justified as there was no evidence of the assessee benefiting from the inaccurate particulars of income. The appeal by the assessee was allowed.
The ITAT, an Appellate Tribunal, considered the levy of penalty u/s 271(1)(c) for disallowance of prior period expenditure and ad hoc disallowance due to non-filing of relevant documents. The assessee inadvertently claimed a higher share of indexed costs of construction and improvement. Citing the case law RELIANCE PETROPRODUCTS PVT. LTD., it was established that a mere claim, even if rejected by the Assessing Officer, does not warrant penalty. The additional indexed costs of improvement claimed by the assessee were found to be inadvertent and did not result in any benefit. Therefore, the penalty was not justified as there was no evidence of the assessee benefiting from the inaccurate particulars of income. The appeal by the assessee was allowed.
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