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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The Appellate Tribunal held that the penalty u/s 271FA for delay in filing the Statement of Financial Transaction (SFT) without reasonable cause was justified. The SFT filing is crucial for tracking high-value financial transactions to prevent tax evasion. The assessee failed to provide a valid reason for the delay in filing, despite notices issued. Compliance with section 285BA is mandatory, and the failure to submit the SFT within the deadline resulted in the penalty being upheld against the assessee.
The Appellate Tribunal held that the penalty u/s 271FA for delay in filing the Statement of Financial Transaction (SFT) without reasonable cause was justified. The SFT filing is crucial for tracking high-value financial transactions to prevent tax evasion. The assessee failed to provide a valid reason for the delay in filing, despite notices issued. Compliance with section 285BA is mandatory, and the failure to submit the SFT within the deadline resulted in the penalty being upheld against the assessee.
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