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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT dismissed the revenue's appeal and affirmed deletion of penalty under s. 271AAB as levied against the assessee. The tribunal upheld the CIT(A)'s factual finding that no search under s. 132 was conducted in the assessee's case; the impugned section predicates penalty liability on initiation of a search. Although the assessee purportedly disclosed the mode of earning the undisclosed income, he had not paid tax for the specified period, but that procedural deficiency does not engage s. 271AAB absent a search. Revenue failed to rebut the finding of no search; accordingly the penalty under s. 271AAB was not sustainable and the appeal was dismissed.
The ITAT dismissed the revenue's appeal and affirmed deletion of penalty under s. 271AAB as levied against the assessee. The tribunal upheld the CIT(A)'s factual finding that no search under s. 132 was conducted in the assessee's case; the impugned section predicates penalty liability on initiation of a search. Although the assessee purportedly disclosed the mode of earning the undisclosed income, he had not paid tax for the specified period, but that procedural deficiency does not engage s. 271AAB absent a search. Revenue failed to rebut the finding of no search; accordingly the penalty under s. 271AAB was not sustainable and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
