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 upheld penalty proceedings under Section 271(1)(c) for concealment and furnishing inaccurate income particulars. The tribunal confirmed CIT's revision order under Section 263, directing reassessment of penalty for professional fees, receipts from a specific company, and personal expenses. The tribunal found no justification to interfere with the original order and dismissed the assessee's appeal, affirming that penalty proceedings were appropriately revived in accordance with Section 275 of the Income Tax Act, 1961, and consistent with prior judicial precedents regarding revenue interests.
ITAT upheld penalty proceedings under Section 271(1)(c) for concealment and furnishing inaccurate income particulars. The tribunal confirmed CIT's revision order under Section 263, directing reassessment of penalty for professional fees, receipts from a specific company, and personal expenses. The tribunal found no justification to interfere with the original order and dismissed the assessee's appeal, affirming that penalty proceedings were appropriately revived in accordance with Section 275 of the Income Tax Act, 1961, and consistent with prior judicial precedents regarding revenue interests.
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