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 reversed penalty imposed under s271I for non-submission of Form 15CA/15CB regarding overseas transactions. Following precedent in M/s Vinay Diamond matter, tribunal acknowledged CBDT Notification GSR 978(E) which exempts certain payments from Form 15CA/15CB filing requirements. Specifically, advance payments against imports fall under exempted categories per Rule 37BB. Tribunal concluded penalty cannot be levied for import-related payments, ruling in appellant's favor. Decision reinforces regulatory exemptions for specified international transactions and clarifies compliance obligations for cross-border advance payments.
ITAT reversed penalty imposed under s271I for non-submission of Form 15CA/15CB regarding overseas transactions. Following precedent in M/s Vinay Diamond matter, tribunal acknowledged CBDT Notification GSR 978(E) which exempts certain payments from Form 15CA/15CB filing requirements. Specifically, advance payments against imports fall under exempted categories per Rule 37BB. Tribunal concluded penalty cannot be levied for import-related payments, ruling in appellant's favor. Decision reinforces regulatory exemptions for specified international transactions and clarifies compliance obligations for cross-border advance payments.
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