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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HC held that the assessee demonstrated reasonable cause under Section 273B for repaying a loan exceeding twenty thousand rupees, thereby exempting them from penalty under Section 271E. The court found the transaction was bona fide, based on a financial institution's insistence to pay in cash. The loan repayment was genuine and not intended to avoid tax liability. Consequently, the penalty orders passed by the Assessing Officer and appellate authorities were set aside, with the substantial question of law decided in favor of the assessee.
HC held that the assessee demonstrated reasonable cause under Section 273B for repaying a loan exceeding twenty thousand rupees, thereby exempting them from penalty under Section 271E. The court found the transaction was bona fide, based on a financial institution's insistence to pay in cash. The loan repayment was genuine and not intended to avoid tax liability. Consequently, the penalty orders passed by the Assessing Officer and appellate authorities were set aside, with the substantial question of law decided in favor of the assessee.
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