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 case involving penalty under section 271D for alleged violation of section 269SS. The tribunal determined that the assessee's receipt of cash for immovable property sale, executed before a government registration authority, did not constitute a statutory breach. The tribunal exercised judicial discretion, recognizing the assessee's bonafide belief regarding the applicability of statutory provisions. Considering the technical nature of the alleged violation and following precedential reasoning, the tribunal deleted the penalty imposed under section 271D, emphasizing that statutory obligations must be interpreted with contextual understanding and reasonable interpretation.
ITAT adjudicated a case involving penalty under section 271D for alleged violation of section 269SS. The tribunal determined that the assessee's receipt of cash for immovable property sale, executed before a government registration authority, did not constitute a statutory breach. The tribunal exercised judicial discretion, recognizing the assessee's bonafide belief regarding the applicability of statutory provisions. Considering the technical nature of the alleged violation and following precedential reasoning, the tribunal deleted the penalty imposed under section 271D, emphasizing that statutory obligations must be interpreted with contextual understanding and reasonable interpretation.
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