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 penalty under section 271(1)(c) for concealment of income cannot be sustained where the assessee filed return in response to section 148 notice and computed long-term capital loss after considering section 50C and pre-indexed cost of improvements. Since the capital gains computation resulted in a loss and no tax liability arose, the foundational addition for imposing penalty ceased to exist. The Tribunal relied on established legal principles that penalty under section 271(1)(c) cannot survive if the quantum addition is deleted or substantially modified to extinguish tax liability. Consequently, the appeal of the assessee was allowed, and the penalty was set aside.
The ITAT held that penalty under section 271(1)(c) for concealment of income cannot be sustained where the assessee filed return in response to section 148 notice and computed long-term capital loss after considering section 50C and pre-indexed cost of improvements. Since the capital gains computation resulted in a loss and no tax liability arose, the foundational addition for imposing penalty ceased to exist. The Tribunal relied on established legal principles that penalty under section 271(1)(c) cannot survive if the quantum addition is deleted or substantially modified to extinguish tax liability. Consequently, the appeal of the assessee was allowed, and the penalty was set aside.
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