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 set aside the penalty under section 271(1)(c) imposed for disallowing deduction under section 80P relating to interest on staff advances and miscellaneous income. The tribunal found that the assessee had accurately disclosed the relevant particulars in the return, computation, and financial statements, including the disputed treatment of interest on staff advances. The AO's conclusion of concealment or furnishing inaccurate particulars was unfounded as the interest was reflected in the Profit & Loss account. Following established precedent, the ITAT held that mere erroneous claims do not constitute inaccurate particulars absent proof of false or incorrect information. Consequently, the penalty was quashed, and the appeal was allowed in favor of the assessee.
The ITAT set aside the penalty under section 271(1)(c) imposed for disallowing deduction under section 80P relating to interest on staff advances and miscellaneous income. The tribunal found that the assessee had accurately disclosed the relevant particulars in the return, computation, and financial statements, including the disputed treatment of interest on staff advances. The AO's conclusion of concealment or furnishing inaccurate particulars was unfounded as the interest was reflected in the Profit & Loss account. Following established precedent, the ITAT held that mere erroneous claims do not constitute inaccurate particulars absent proof of false or incorrect information. Consequently, the penalty was quashed, and the appeal was allowed in favor of the assessee.
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