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 imposed under section 271(1)(c) relating to TDS under section 195 on payments made to associated enterprises for online advertisement purchases, which were treated as Fees for Technical Services. The Tribunal noted that requisite forms (15C and 15CB) were filed for all transactions, and no prior penal action was initiated under TDS provisions. It emphasized that such online advertisement payments from abroad are not taxable under the Income Tax Act or relevant DTAA, corroborated by the introduction of the Equalization Levy under the Finance Act, 2016. The Tribunal held that the dispute involved a bona fide difference of opinion rather than concealment or misreporting of facts. Given that the CIT(A) allowed part of the transactions, the penalty was unwarranted. Consequently, the appeal was allowed, and the penalty was quashed.
The ITAT set aside the penalty imposed under section 271(1)(c) relating to TDS under section 195 on payments made to associated enterprises for online advertisement purchases, which were treated as Fees for Technical Services. The Tribunal noted that requisite forms (15C and 15CB) were filed for all transactions, and no prior penal action was initiated under TDS provisions. It emphasized that such online advertisement payments from abroad are not taxable under the Income Tax Act or relevant DTAA, corroborated by the introduction of the Equalization Levy under the Finance Act, 2016. The Tribunal held that the dispute involved a bona fide difference of opinion rather than concealment or misreporting of facts. Given that the CIT(A) allowed part of the transactions, the penalty was unwarranted. Consequently, the appeal was allowed, and the penalty was quashed.
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