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 271(1)(c) was imposed despite the assessee withdrawing the exemption claim u/s 10(38) for Long Term Capital Gain (LTCG) on sale of penny stocks and offering the corresponding amount as income from "Other sources" in the return filed in response to notice u/s 148. The Tribunal held that the Assessing Officer failed to dislodge the bona fide explanation of the assessee for withdrawing the LTCG exemption claim and offering the amount as income from "Other sources". Explanation 3 to Section 271(1)(c) deems income disclosed in the return filed u/s 148 as concealed income only in specific circumstances, which were not applicable in the assessee's case. No inaccurate particulars or concealment of income were found, and the assessee withdrew the exemption claim and offered the amount as income to avoid litigation. Since penalty proceedings u/s 271(1)(c) are quasi-criminal, the assessee cannot be penalized in the absence of conclusive evidence of furnishing false particulars.
Penalty u/s 271(1)(c) was imposed despite the assessee withdrawing the exemption claim u/s 10(38) for Long Term Capital Gain (LTCG) on sale of penny stocks and offering the corresponding amount as income from "Other sources" in the return filed in response to notice u/s 148. The Tribunal held that the Assessing Officer failed to dislodge the bona fide explanation of the assessee for withdrawing the LTCG exemption claim and offering the amount as income from "Other sources". Explanation 3 to Section 271(1)(c) deems income disclosed in the return filed u/s 148 as concealed income only in specific circumstances, which were not applicable in the assessee's case. No inaccurate particulars or concealment of income were found, and the assessee withdrew the exemption claim and offered the amount as income to avoid litigation. Since penalty proceedings u/s 271(1)(c) are quasi-criminal, the assessee cannot be penalized in the absence of conclusive evidence of furnishing false particulars.
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