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 dismissed the assessee's appeal against penalty levied u/s 271C for failure to deduct tax at source on LTC/LFC reimbursements paid to employees for foreign travel. The assessee, a leading banking institution, failed to establish reasonable cause u/s 273B for non-deduction of TDS. ITAT rejected the assessee's contention of bonafide belief that tax was not deductible at source, holding that a major corporate entity with adequate intellectual resources cannot claim lack of knowledge as reasonable cause. The Tribunal found no material to interfere with CIT(A)'s order confirming the penalty, emphasizing that failure to exercise due diligence despite availability of informed resources cannot constitute reasonable explanation for TDS non-compliance.
ITAT dismissed the assessee's appeal against penalty levied u/s 271C for failure to deduct tax at source on LTC/LFC reimbursements paid to employees for foreign travel. The assessee, a leading banking institution, failed to establish reasonable cause u/s 273B for non-deduction of TDS. ITAT rejected the assessee's contention of bonafide belief that tax was not deductible at source, holding that a major corporate entity with adequate intellectual resources cannot claim lack of knowledge as reasonable cause. The Tribunal found no material to interfere with CIT(A)'s order confirming the penalty, emphasizing that failure to exercise due diligence despite availability of informed resources cannot constitute reasonable explanation for TDS non-compliance.
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