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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The ITAT allowed the appellant's appeal, deleting the Rs. 10,00,000/- penalty imposed under Section 43 of the Black Money Act. The Tribunal found that the appellant, a British citizen who was only a tax resident in India for the relevant assessment year, had disclosed the foreign asset in a timely filed revised return. The revenue authorities failed to establish that the appellant was previously an Indian citizen or that the foreign investment involved undisclosed income from India. Relying on K Mohammad Haris and Rohit Krishna precedents, the ITAT concluded that the legislative intent of the Black Money Act was not applicable in this case, as there was proper disclosure within the prescribed time limit.
The ITAT allowed the appellant's appeal, deleting the Rs. 10,00,000/- penalty imposed under Section 43 of the Black Money Act. The Tribunal found that the appellant, a British citizen who was only a tax resident in India for the relevant assessment year, had disclosed the foreign asset in a timely filed revised return. The revenue authorities failed to establish that the appellant was previously an Indian citizen or that the foreign investment involved undisclosed income from India. Relying on K Mohammad Haris and Rohit Krishna precedents, the ITAT concluded that the legislative intent of the Black Money Act was not applicable in this case, as there was proper disclosure within the prescribed time limit.
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