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 allowed the assessee's appeal, finding that the statutory notice under section 142(1) was not sent to the registered email addresses as defined in Explanation (t) to section 144B. The tribunal determined the assessee's explanation constituted "reasonable cause" under section 273B, thereby directing deletion of the penalty levied under section 271(1)(b). The tribunal recognized the procedural non-compliance by the revenue department in serving the notice, which effectively invalidated the penalty proceedings against the assessee.
ITAT allowed the assessee's appeal, finding that the statutory notice under section 142(1) was not sent to the registered email addresses as defined in Explanation (t) to section 144B. The tribunal determined the assessee's explanation constituted "reasonable cause" under section 273B, thereby directing deletion of the penalty levied under section 271(1)(b). The tribunal recognized the procedural non-compliance by the revenue department in serving the notice, which effectively invalidated the penalty proceedings against the assessee.
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