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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No penalty u/s 271(1)(c) was imposed on the assessee for disallowance of depreciation. The ITAT held that the assessee did not deliberately claim depreciation with an intention to make an inaccurate claim, as evidenced by the voluntary withdrawal of the ground before the CIT(A) and non-claiming of depreciation in subsequent years. The ITAT relied on the Supreme Court's decision in CIT vs. Pricewaterhouse Coopers Pvt. Ltd., which held that no penalty u/s 271(1)(c) would be imposed for a bona fide, inadvertent, or human error. The ITAT ruled in favor of the assessee.
No penalty u/s 271(1)(c) was imposed on the assessee for disallowance of depreciation. The ITAT held that the assessee did not deliberately claim depreciation with an intention to make an inaccurate claim, as evidenced by the voluntary withdrawal of the ground before the CIT(A) and non-claiming of depreciation in subsequent years. The ITAT relied on the Supreme Court's decision in CIT vs. Pricewaterhouse Coopers Pvt. Ltd., which held that no penalty u/s 271(1)(c) would be imposed for a bona fide, inadvertent, or human error. The ITAT ruled in favor of the assessee.
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