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 held that the penalty order under section 271D was time-barred. The AO issued reference to the JCIT on 31.07.2019, and following Mahesh Wood Products, the penalty order should have been passed within six months (by 31.01.2020). Since the JCIT passed the order on 28.02.2020, it exceeded the prescribed limitation period under section 275(1)(c). The Tribunal determined this rendered the penalty order invalid. The second contention regarding non-submission of demand notice alongside the penalty order was deemed academic since the assessee had already succeeded on the first ground. The appeal was decided in favor of the assessee.
The ITAT held that the penalty order under section 271D was time-barred. The AO issued reference to the JCIT on 31.07.2019, and following Mahesh Wood Products, the penalty order should have been passed within six months (by 31.01.2020). Since the JCIT passed the order on 28.02.2020, it exceeded the prescribed limitation period under section 275(1)(c). The Tribunal determined this rendered the penalty order invalid. The second contention regarding non-submission of demand notice alongside the penalty order was deemed academic since the assessee had already succeeded on the first ground. The appeal was decided in favor of the assessee.
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