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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ITAT allowed the appeal of the taxpayer and set aside the penalty under s.271B for belated filing of the tax audit report, holding that reasonable cause existed. The Tribunal found the delay resulted from the statutory report being awaited from the State government and that the belated filing on 20.03.2017 was not a deliberate contravention. In light of prevailing precedent and absence of distinguishing facts or law urged by the Revenue, the Tribunal concluded that imposition of penalty was unwarranted and ordered deletion of the penalty. The appeal by the assessee was therefore allowed.
ITAT allowed the appeal of the taxpayer and set aside the penalty under s.271B for belated filing of the tax audit report, holding that reasonable cause existed. The Tribunal found the delay resulted from the statutory report being awaited from the State government and that the belated filing on 20.03.2017 was not a deliberate contravention. In light of prevailing precedent and absence of distinguishing facts or law urged by the Revenue, the Tribunal concluded that imposition of penalty was unwarranted and ordered deletion of the penalty. The appeal by the assessee was therefore allowed.
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