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 held that penalty u/s 270A(9)(a) for under-reporting of income is deleted. The appellant, a salaried employee, demonstrated a bona fide mistake by relying on tax representative's advice and TDS portal figures. Given the taxpayer's full tax payment, reliance on official portal data, and genuine error, the tribunal found no intentional misreporting. The 200% penalty initially imposed by the Assessing Officer was consequently nullified, with the decision rendered in favor of the assessee based on mitigating circumstances.
ITAT held that penalty u/s 270A(9)(a) for under-reporting of income is deleted. The appellant, a salaried employee, demonstrated a bona fide mistake by relying on tax representative's advice and TDS portal figures. Given the taxpayer's full tax payment, reliance on official portal data, and genuine error, the tribunal found no intentional misreporting. The 200% penalty initially imposed by the Assessing Officer was consequently nullified, with the decision rendered in favor of the assessee based on mitigating circumstances.
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