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 made repayments of loans/deposits through modes other than account payee cheques/drafts, violating Section 269T. Penalty u/s 271E was imposed. ITAT bifurcated transactions into those with related parties and Customer Sales Agents (CSAs). For CSA transactions, outstanding dues were adjusted against security deposits through journal entries, breaching Section 269SS. However, ITAT held this constituted 'reasonable cause' u/s 273B, not attracting penalty u/s 271E, relying on Ajitnath Hi-Tech Builders (P.) Ltd. [2018 (2) TMI 603 - Bombay HC]. Consequently, ITAT set aside CIT(A)'s order and directed AO to delete penalty levied u/s 271E, deciding in favor of assessee.
Assessee made repayments of loans/deposits through modes other than account payee cheques/drafts, violating Section 269T. Penalty u/s 271E was imposed. ITAT bifurcated transactions into those with related parties and Customer Sales Agents (CSAs). For CSA transactions, outstanding dues were adjusted against security deposits through journal entries, breaching Section 269SS. However, ITAT held this constituted 'reasonable cause' u/s 273B, not attracting penalty u/s 271E, relying on Ajitnath Hi-Tech Builders (P.) Ltd. [2018 (2) TMI 603 - Bombay HC]. Consequently, ITAT set aside CIT(A)'s order and directed AO to delete penalty levied u/s 271E, deciding in favor of assessee.
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