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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The ITAT upheld the penalty under section 271(1)(c) imposed on the assessee for concealing/furnishing inaccurate particulars of income by claiming depreciation on inflated and bogus asset purchases. The tribunal rejected the assessee's contention that no penalty should apply to the disallowance related to inflated asset costs, despite a favorable quantum decision in a separate case, finding no merit in this argument. Regarding depreciation on bogus assets, the tribunal noted the assessee's acceptance of the CIT(A) order and affirmed the findings that the purchased assets were from non-genuine parties, corroborated by departmental investigations and admissions from associated group officials. The tribunal distinguished the present facts from the cited case relied upon by the assessee, concluding no relief was warranted. Consequently, the ITAT confirmed the levy of penalty on disallowed depreciation pertaining to both inflated and bogus asset purchases.
The ITAT upheld the penalty under section 271(1)(c) imposed on the assessee for concealing/furnishing inaccurate particulars of income by claiming depreciation on inflated and bogus asset purchases. The tribunal rejected the assessee's contention that no penalty should apply to the disallowance related to inflated asset costs, despite a favorable quantum decision in a separate case, finding no merit in this argument. Regarding depreciation on bogus assets, the tribunal noted the assessee's acceptance of the CIT(A) order and affirmed the findings that the purchased assets were from non-genuine parties, corroborated by departmental investigations and admissions from associated group officials. The tribunal distinguished the present facts from the cited case relied upon by the assessee, concluding no relief was warranted. Consequently, the ITAT confirmed the levy of penalty on disallowed depreciation pertaining to both inflated and bogus asset purchases.
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