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) is not sustainable when assessee voluntarily revised ITR before notice u/s 153A and the additional income was accepted by AO without specific linkage to seized materials. The tribunal followed precedent establishing that revised return post-search takes place of original return, and higher income declaration does not automatically attract penalty. Appeal by assessee allowed, penalty deleted.
ITAT held that penalty u/s 271(1)(c) is not sustainable when assessee voluntarily revised ITR before notice u/s 153A and the additional income was accepted by AO without specific linkage to seized materials. The tribunal followed precedent establishing that revised return post-search takes place of original return, and higher income declaration does not automatically attract penalty. Appeal by assessee allowed, penalty deleted.
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