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 the Assessing Officer's rectification order regarding interest calculation under Section 234A(1)(a). The assessee failed to file returns by the due date of September 30, 2011, and only submitted returns on May 10, 2018, following a Section 148 notice. The period of default was correctly revised from one month to eighty months. Interest was chargeable for every month or part thereof from the day after the due date until the actual filing date. The Tribunal confirmed the AO's computation was in accordance with statutory provisions, finding no grounds for interference with the rectification order. The appeal was dismissed with costs against the assessee.
ITAT upheld the Assessing Officer's rectification order regarding interest calculation under Section 234A(1)(a). The assessee failed to file returns by the due date of September 30, 2011, and only submitted returns on May 10, 2018, following a Section 148 notice. The period of default was correctly revised from one month to eighty months. Interest was chargeable for every month or part thereof from the day after the due date until the actual filing date. The Tribunal confirmed the AO's computation was in accordance with statutory provisions, finding no grounds for interference with the rectification order. The appeal was dismissed with costs against the assessee.
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