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 held that penalty u/s 271(1)(c) was not sustainable where the assessee voluntarily disclosed correct income and paid due tax before receiving notice u/s 148. The tribunal found that tax and interest were deposited on 27-05-2019, predating the notice issued on 03-03-2020. The assessee's arguments were accepted, emphasizing that the income tax payment was made prior to the statutory notice, rendering the penalty inappropriate. Consequently, the grounds of appeal were allowed, effectively quashing the penalty proceedings against the taxpayer.
ITAT held that penalty u/s 271(1)(c) was not sustainable where the assessee voluntarily disclosed correct income and paid due tax before receiving notice u/s 148. The tribunal found that tax and interest were deposited on 27-05-2019, predating the notice issued on 03-03-2020. The assessee's arguments were accepted, emphasizing that the income tax payment was made prior to the statutory notice, rendering the penalty inappropriate. Consequently, the grounds of appeal were allowed, effectively quashing the penalty proceedings against the taxpayer.
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