Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
AO levied penalty u/s 271(1)(c) as assessee failed to file return u/s 139 or in response to notice u/s 148, despite receiving substantial contract receipts of Rs. 2.5 crore. ITAT upheld penalty, rejecting assessee's plea that addition was estimated, as assessee defied statutory requirements and didn't furnish details during assessment proceedings. Assessee's contention of auditor's failure being the cause was rejected, as filing return u/s 139 is assessee's responsibility. Penalty confirmed.
AO levied penalty u/s 271(1)(c) as assessee failed to file return u/s 139 or in response to notice u/s 148, despite receiving substantial contract receipts of Rs. 2.5 crore. ITAT upheld penalty, rejecting assessee's plea that addition was estimated, as assessee defied statutory requirements and didn't furnish details during assessment proceedings. Assessee's contention of auditor's failure being the cause was rejected, as filing return u/s 139 is assessee's responsibility. Penalty confirmed.
Note: It is a system-generated summary and is for quick reference only.