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 errors in the assessee's quarterly TDS returns were typographical and did not demonstrate any willful attempt to evade tax or defraud the revenue. The AO's issuance of a single consolidated penalty order under section 271C for multiple assessment years and quarters was found to be legally impermissible, rendering the order void ab initio. Consequently, the levy of penalty under section 271C was quashed, and the assessee's appeal was allowed.
The ITAT held that the errors in the assessee's quarterly TDS returns were typographical and did not demonstrate any willful attempt to evade tax or defraud the revenue. The AO's issuance of a single consolidated penalty order under section 271C for multiple assessment years and quarters was found to be legally impermissible, rendering the order void ab initio. Consequently, the levy of penalty under section 271C was quashed, and the assessee's appeal was allowed.
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