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...
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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 assessee's appeal and deleted the penalty imposed under section 271AAB regarding seized cash during a search operation. The Tribunal found that the AO failed to satisfy the statutory requirements under section 271AAB. The ITAT distinguished the present case from Pr. CIT v. Sandeep Chandak, noting that the Revenue's reliance on Veena Estate Pvt. Ltd. was misplaced as that decision did not specifically address search penalties under section 271AAB. The Tribunal also observed that the main appeal in the Veena Estate case remained pending before the Bombay HC. Consequently, the impugned penalty was deleted due to the AO's failure to fulfill the necessary conditions under section 271AAB.
The ITAT allowed the assessee's appeal and deleted the penalty imposed under section 271AAB regarding seized cash during a search operation. The Tribunal found that the AO failed to satisfy the statutory requirements under section 271AAB. The ITAT distinguished the present case from Pr. CIT v. Sandeep Chandak, noting that the Revenue's reliance on Veena Estate Pvt. Ltd. was misplaced as that decision did not specifically address search penalties under section 271AAB. The Tribunal also observed that the main appeal in the Veena Estate case remained pending before the Bombay HC. Consequently, the impugned penalty was deleted due to the AO's failure to fulfill the necessary conditions under section 271AAB.
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