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 allowed the assessee's appeal and deleted penalty under section 271AAA. The AO imposed penalty alleging the assessee failed to substantiate the manner of deriving undisclosed income surrendered during search proceedings. The assessee contended that the Authorized Officer never specifically asked to specify the derivation manner during search. ITAT found that no specific question was put to the assessee regarding the mode and manner of earning undisclosed income during the recorded statement. Following precedent from a group case with similar facts where ITAT Chandigarh Bench confirmed CIT(A)'s deletion of section 271AAA penalty for identical reasons, the tribunal deleted the penalty. The decision established that without specific questioning during search about income derivation methods, penalty under section 271AAA cannot be sustained.
ITAT allowed the assessee's appeal and deleted penalty under section 271AAA. The AO imposed penalty alleging the assessee failed to substantiate the manner of deriving undisclosed income surrendered during search proceedings. The assessee contended that the Authorized Officer never specifically asked to specify the derivation manner during search. ITAT found that no specific question was put to the assessee regarding the mode and manner of earning undisclosed income during the recorded statement. Following precedent from a group case with similar facts where ITAT Chandigarh Bench confirmed CIT(A)'s deletion of section 271AAA penalty for identical reasons, the tribunal deleted the penalty. The decision established that without specific questioning during search about income derivation methods, penalty under section 271AAA cannot be sustained.
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