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 penalty case under Section 272A(2)(e) regarding non-filing of income tax return. The tribunal directed the CIT(Appeals) to re-examine the assessee's claim of exemption under Section 10(23C)(iiiad), which potentially absolves them from mandatory return filing. The tribunal noted the assessee's failure to provide substantive reasons for non-compliance and insufficient explanation for the delay. The matter was remanded for de novo adjudication, requiring the assessee to present comprehensive evidence and rationale for challenging the proposed penalty. The CIT(Appeals) is mandated to conduct a fresh merit-based assessment of the penalty proceedings.
ITAT adjudicated a penalty case under Section 272A(2)(e) regarding non-filing of income tax return. The tribunal directed the CIT(Appeals) to re-examine the assessee's claim of exemption under Section 10(23C)(iiiad), which potentially absolves them from mandatory return filing. The tribunal noted the assessee's failure to provide substantive reasons for non-compliance and insufficient explanation for the delay. The matter was remanded for de novo adjudication, requiring the assessee to present comprehensive evidence and rationale for challenging the proposed penalty. The CIT(Appeals) is mandated to conduct a fresh merit-based assessment of the penalty proceedings.
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