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 appellant's appeal and deleted the penalty imposed under section 271B for delayed submission of audit report. The tribunal held that penalty cannot be levied when the audit report is submitted before completion of assessment proceedings. Additionally, the appellant established reasonable cause for the delay, specifically attending to his son's illness, which prevented timely filing. The tribunal relied on precedent recognizing ill health of family members as reasonable cause under section 273B. The decision emphasized that genuine personal circumstances constituting reasonable cause preclude penalty imposition for procedural delays in tax compliance matters.
ITAT allowed the appellant's appeal and deleted the penalty imposed under section 271B for delayed submission of audit report. The tribunal held that penalty cannot be levied when the audit report is submitted before completion of assessment proceedings. Additionally, the appellant established reasonable cause for the delay, specifically attending to his son's illness, which prevented timely filing. The tribunal relied on precedent recognizing ill health of family members as reasonable cause under section 273B. The decision emphasized that genuine personal circumstances constituting reasonable cause preclude penalty imposition for procedural delays in tax compliance matters.
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