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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HC allowed assessee's appeal against penalty under Section 271(1)(c) of the Income Tax Act. The assessee claimed deduction for crystallized liability towards additional bonus, which was subsequently disallowed under Section 43B as payment was made in the following accounting year. The court held that neither concealment of income particulars nor furnishing inaccurate particulars were established. The assessee's claim was bona fide and plausible, based on crystallized future liability, not a false statement. The disallowance was due to timing provisions under Section 43B, not mala fide concealment. The court distinguished this from cases involving false claims, emphasizing that raising a legally plausible claim, even if ultimately unsustainable, cannot attract penalty provisions. Essential ingredients of Section 271(1)(c) were not satisfied.
HC allowed assessee's appeal against penalty under Section 271(1)(c) of the Income Tax Act. The assessee claimed deduction for crystallized liability towards additional bonus, which was subsequently disallowed under Section 43B as payment was made in the following accounting year. The court held that neither concealment of income particulars nor furnishing inaccurate particulars were established. The assessee's claim was bona fide and plausible, based on crystallized future liability, not a false statement. The disallowance was due to timing provisions under Section 43B, not mala fide concealment. The court distinguished this from cases involving false claims, emphasizing that raising a legally plausible claim, even if ultimately unsustainable, cannot attract penalty provisions. Essential ingredients of Section 271(1)(c) were not satisfied.
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