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 tax collection at source (TCS) penalty case involving coal and lignite sales. The tribunal found reasonable cause under Section 273B for delayed TCS compliance, noting the taxpayer had ultimately deposited Rs. 87,750/- in the same financial year and the delay resulted from personnel illness. Despite initial non-compliance, the taxpayer submitted challans evidencing payment. The tribunal set aside the CIT(A) order, directing the Assessing Officer to delete the penalty levy, thereby accepting the taxpayer's contention of reasonable cause and procedural irregularity. The penalty under Section 271CA was consequently quashed.
ITAT adjudicated a tax collection at source (TCS) penalty case involving coal and lignite sales. The tribunal found reasonable cause under Section 273B for delayed TCS compliance, noting the taxpayer had ultimately deposited Rs. 87,750/- in the same financial year and the delay resulted from personnel illness. Despite initial non-compliance, the taxpayer submitted challans evidencing payment. The tribunal set aside the CIT(A) order, directing the Assessing Officer to delete the penalty levy, thereby accepting the taxpayer's contention of reasonable cause and procedural irregularity. The penalty under Section 271CA was consequently quashed.
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