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 ruled in favor of the assessee, quashing the penalty order under Section 271B for procedural irregularities. The tribunal found that the penalty notice was issued beyond prescribed time limitations per Section 275, and the Assessing Officer failed to substantiate specific accounting defects. The order lacked precise charges of default and was time-barred. Consequently, the tribunal directed the AO to delete the imposed penalty, emphasizing procedural fairness and strict adherence to statutory timelines in penalty proceedings.
ITAT ruled in favor of the assessee, quashing the penalty order under Section 271B for procedural irregularities. The tribunal found that the penalty notice was issued beyond prescribed time limitations per Section 275, and the Assessing Officer failed to substantiate specific accounting defects. The order lacked precise charges of default and was time-barred. Consequently, the tribunal directed the AO to delete the imposed penalty, emphasizing procedural fairness and strict adherence to statutory timelines in penalty proceedings.
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