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 held that penalty under s.270A was unsustainable and set aside because the AO, in the s.274 notice and penalty order, failed to specify the precise default-whether "under-reporting" or "under-reporting as a consequence of misreporting"-each attracting distinct penal consequences and rates; issuance of a notice alleging both distinct defaults rendered the proceedings void ab initio. Given the absence of identification of the exact charge, the penalty could not be validly levied. Accordingly, the assessee's appeal was allowed and the penalty order annulled.
ITAT held that penalty under s.270A was unsustainable and set aside because the AO, in the s.274 notice and penalty order, failed to specify the precise default-whether "under-reporting" or "under-reporting as a consequence of misreporting"-each attracting distinct penal consequences and rates; issuance of a notice alleging both distinct defaults rendered the proceedings void ab initio. Given the absence of identification of the exact charge, the penalty could not be validly levied. Accordingly, the assessee's appeal was allowed and the penalty order annulled.
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