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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ITAT upheld penalty under s271B for failure to furnish tax audit report per s44AB requirements. Assessee's turnover of Rs.8,53,66,166/- exceeded statutory threshold, mandating tax audit. Claims of substantial losses, creditor payments, and partners being senior citizens were rejected as insufficient reasonable cause for non-compliance. A purported tax audit report dated 23.09.2013 submitted later was dismissed as not previously presented to lower authorities. Assessee's incomplete documentation, lacking profit-loss statements and balance sheets, undermined their position. The contradictory claim of timely audit completion was rejected. Precedents cited by assessee were distinguished on facts. Penalty order sustained as assessee failed to demonstrate reasonable cause for non-compliance with statutory audit requirements.
ITAT upheld penalty under s271B for failure to furnish tax audit report per s44AB requirements. Assessee's turnover of Rs.8,53,66,166/- exceeded statutory threshold, mandating tax audit. Claims of substantial losses, creditor payments, and partners being senior citizens were rejected as insufficient reasonable cause for non-compliance. A purported tax audit report dated 23.09.2013 submitted later was dismissed as not previously presented to lower authorities. Assessee's incomplete documentation, lacking profit-loss statements and balance sheets, undermined their position. The contradictory claim of timely audit completion was rejected. Precedents cited by assessee were distinguished on facts. Penalty order sustained as assessee failed to demonstrate reasonable cause for non-compliance with statutory audit requirements.
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