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's cash repayment of loan to the finance corporation, made on lender's instruction to arrest interest escalation, constitutes reasonable cause under Section 273B. The court found that all three tax authorities erroneously imposed penalty under Section 271E without considering Section 273B, which provides exemption when genuine reasonable cause exists. The transaction was deemed bona fide, and no revenue loss occurred. The penalty orders by AO, CIT(Appeals), and ITAT were consequently set aside, with the ruling decisively favoring the assessee's interpretation of reasonable cause in tax compliance.
HC held that the assessee's cash repayment of loan to the finance corporation, made on lender's instruction to arrest interest escalation, constitutes reasonable cause under Section 273B. The court found that all three tax authorities erroneously imposed penalty under Section 271E without considering Section 273B, which provides exemption when genuine reasonable cause exists. The transaction was deemed bona fide, and no revenue loss occurred. The penalty orders by AO, CIT(Appeals), and ITAT were consequently set aside, with the ruling decisively favoring the assessee's interpretation of reasonable cause in tax compliance.
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