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 deletion of penalties under s271(1)(c) and s270A regarding non-deduction of TDS on External Development Charges paid to HUDA. While assessee did not contest the s40(a)(ia) disallowance, they provided reasonable explanation that legal clarity was lacking on TDS applicability to EDC payments at the relevant time. No evidence suggested non-genuine payments or income concealment. Mere non-compliance with TDS provisions does not constitute concealment or furnishing inaccurate income particulars. Making incorrect legal claims does not amount to providing inaccurate details, following Reliance Petroproducts precedent. CIT(A)'s order deleting both penalties was upheld, ruling in assessee's favor.
ITAT upheld deletion of penalties under s271(1)(c) and s270A regarding non-deduction of TDS on External Development Charges paid to HUDA. While assessee did not contest the s40(a)(ia) disallowance, they provided reasonable explanation that legal clarity was lacking on TDS applicability to EDC payments at the relevant time. No evidence suggested non-genuine payments or income concealment. Mere non-compliance with TDS provisions does not constitute concealment or furnishing inaccurate income particulars. Making incorrect legal claims does not amount to providing inaccurate details, following Reliance Petroproducts precedent. CIT(A)'s order deleting both penalties was upheld, ruling in assessee's favor.
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