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 held that the assessee's repayment of loan EMIs in cash to an NBFC, a practice followed upon default, constituted reasonable cause under section 273B. The tribunal found the CIT(A) erred in rejecting the assessee's explanation for cash payments. Since the penalty under section 271E relates to the entire addition and the assessee satisfactorily demonstrated justification for the cash repayments, the penalty was deleted. The assessee's appeal was allowed, resulting in the quashing of the penalty imposed for repayment of loan in cash otherwise than by prescribed modes.
The ITAT held that the assessee's repayment of loan EMIs in cash to an NBFC, a practice followed upon default, constituted reasonable cause under section 273B. The tribunal found the CIT(A) erred in rejecting the assessee's explanation for cash payments. Since the penalty under section 271E relates to the entire addition and the assessee satisfactorily demonstrated justification for the cash repayments, the penalty was deleted. The assessee's appeal was allowed, resulting in the quashing of the penalty imposed for repayment of loan in cash otherwise than by prescribed modes.
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