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 adjudicated a case involving penalty under Section 43 of the Black Money Act for non-reporting of foreign assets in Schedule FA. Despite technical non-disclosure, the tribunal found no malafide intention as the assessee had previously disclosed the foreign asset, offered perquisite value, and paid TDS. The tribunal emphasized that the Act's purpose is to address undisclosed foreign income, not to punish bonafide technical breaches. Considering the assessee's transparent actions and detailed explanations, the tribunal deleted the imposed penalty, effectively allowing the assessee's appeal and recognizing the difference between intentional concealment and inadvertent procedural omission.
ITAT adjudicated a case involving penalty under Section 43 of the Black Money Act for non-reporting of foreign assets in Schedule FA. Despite technical non-disclosure, the tribunal found no malafide intention as the assessee had previously disclosed the foreign asset, offered perquisite value, and paid TDS. The tribunal emphasized that the Act's purpose is to address undisclosed foreign income, not to punish bonafide technical breaches. Considering the assessee's transparent actions and detailed explanations, the tribunal deleted the imposed penalty, effectively allowing the assessee's appeal and recognizing the difference between intentional concealment and inadvertent procedural omission.
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