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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT reversed CIT(A)'s deletion of penalty under s271AAB imposed during search and seizure proceedings. The company director had declared undisclosed income, but CIT(A) deleted penalty citing vague show cause notices. ITAT found AO had clearly specified penalty charges under s271AAB(1A) in both assessment and penalty orders, properly notifying assessee of proceedings and undisclosed amount. Computer-generated notice limitations were acknowledged. Following precedents from Allahabad HC and ITAT Pune, tribunal held CIT(A)'s order unsustainable, reinstating penalty. Revenue's appeal allowed, emphasizing sufficient specification of charges despite standardized notice format.
ITAT reversed CIT(A)'s deletion of penalty under s271AAB imposed during search and seizure proceedings. The company director had declared undisclosed income, but CIT(A) deleted penalty citing vague show cause notices. ITAT found AO had clearly specified penalty charges under s271AAB(1A) in both assessment and penalty orders, properly notifying assessee of proceedings and undisclosed amount. Computer-generated notice limitations were acknowledged. Following precedents from Allahabad HC and ITAT Pune, tribunal held CIT(A)'s order unsustainable, reinstating penalty. Revenue's appeal allowed, emphasizing sufficient specification of charges despite standardized notice format.
Note: It is a system-generated summary and is for quick reference only.