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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This case deals with the penalty u/s 271(1)(c) of the Income Tax Act, imposed for disallowance of losses on forex derivatives treated as speculative losses and disallowance of foreign exchange fluctuation loss claimed by the assessee. The Tribunal held that the advice given to the assessee by the consultant cannot be termed as furnishing inaccurate particulars of income attracting penalty u/s 271(1)(c). Relying on the Supreme Court's decision in Reliance Petroproducts Pvt. Ltd., the Tribunal ruled that the penalty levied was not justifiable and deleted the penalty imposed on the assessee, allowing the assessee's appeal.
This case deals with the penalty u/s 271(1)(c) of the Income Tax Act, imposed for disallowance of losses on forex derivatives treated as speculative losses and disallowance of foreign exchange fluctuation loss claimed by the assessee. The Tribunal held that the advice given to the assessee by the consultant cannot be termed as furnishing inaccurate particulars of income attracting penalty u/s 271(1)(c). Relying on the Supreme Court's decision in Reliance Petroproducts Pvt. Ltd., the Tribunal ruled that the penalty levied was not justifiable and deleted the penalty imposed on the assessee, allowing the assessee's appeal.
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