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 penalty case involving tempo transportation income estimation. The tribunal examined the penalty imposed under Section 270A, which was calculated at 7,500 per tempo across 13 tempos, while the assessee actually owned 10 tempos. The tribunal found the penalty order unsustainable, relying on a prior judicial precedent. The estimation methodology was deemed legally flawed, resulting in the penalty being quashed. The assessee's appeal was allowed, effectively nullifying the penalty assessment based on improper income estimation techniques.
ITAT adjudicated a tax penalty case involving tempo transportation income estimation. The tribunal examined the penalty imposed under Section 270A, which was calculated at 7,500 per tempo across 13 tempos, while the assessee actually owned 10 tempos. The tribunal found the penalty order unsustainable, relying on a prior judicial precedent. The estimation methodology was deemed legally flawed, resulting in the penalty being quashed. The assessee's appeal was allowed, effectively nullifying the penalty assessment based on improper income estimation techniques.
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