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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Assessee not liable for penalties u/s 271E/271D for violation of sections 269SS/269ST by company where she was neither shareholder nor director. ITAT held assessee cannot be fastened with liability for acts/omissions of her deceased husband who was director, as she neither inherited any estate from him nor was involved in company's dealings. Provisions of section 159(6) limit legal representative's liability to extent of assets acquired. Revenue failed to establish assessee received any estate from late husband. Penalties deleted.
Assessee not liable for penalties u/s 271E/271D for violation of sections 269SS/269ST by company where she was neither shareholder nor director. ITAT held assessee cannot be fastened with liability for acts/omissions of her deceased husband who was director, as she neither inherited any estate from him nor was involved in company's dealings. Provisions of section 159(6) limit legal representative's liability to extent of assets acquired. Revenue failed to establish assessee received any estate from late husband. Penalties deleted.
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