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 u/s.270A for underreporting of income based on suppressed sales discovered during survey. Despite partner's initial admission and subsequent retraction, incriminating documents substantiated undisclosed income. The tribunal found no procedural infirmity in penalty imposition, noting the assessee's repeated non-compliance and failure to effectively challenge the revenue's claims. The penalty was directed to be recalculated proportionate to the reduced income quantum, affirming the CIT(A)'s earlier order. The tribunal concluded that the suppressed sales constituted misreporting under section 270A, warranting statutory penalty.
ITAT upheld penalty u/s.270A for underreporting of income based on suppressed sales discovered during survey. Despite partner's initial admission and subsequent retraction, incriminating documents substantiated undisclosed income. The tribunal found no procedural infirmity in penalty imposition, noting the assessee's repeated non-compliance and failure to effectively challenge the revenue's claims. The penalty was directed to be recalculated proportionate to the reduced income quantum, affirming the CIT(A)'s earlier order. The tribunal concluded that the suppressed sales constituted misreporting under section 270A, warranting statutory penalty.
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