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 partially allowed the assessee's appeal, restricting penalty u/s 271B to Rs 10,000/-. The Tribunal acknowledged electronic notice service to the assessee's email ID, which remained unrebutted. Applying established legal principles against double penalty for identical default, the Tribunal referenced precedent to delete the balance penalty. The decision emphasizes procedural fairness by limiting punitive measures to a proportionate quantum, ensuring compliance without excessive financial burden on the taxpayer.
ITAT partially allowed the assessee's appeal, restricting penalty u/s 271B to Rs 10,000/-. The Tribunal acknowledged electronic notice service to the assessee's email ID, which remained unrebutted. Applying established legal principles against double penalty for identical default, the Tribunal referenced precedent to delete the balance penalty. The decision emphasizes procedural fairness by limiting punitive measures to a proportionate quantum, ensuring compliance without excessive financial burden on the taxpayer.
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