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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In penalty proceedings under s.271A for alleged failure to maintain books u/s 44AA arising from derivatives (F&O) trading, ITAT held that the assessee's reliance on ICAI guidance for computing F&O turnover constituted a reasonable cause for non-maintenance of books. The Tribunal found the Income-tax Act lacks specific provisions for F&O turnover computation, accepted the assessee's detailed submissions, and determined that imposition of penalty by the Assessing Officer under s.274 was unjustified. Consequently the penalty was set aside and the assessee's appeal allowed.
In penalty proceedings under s.271A for alleged failure to maintain books u/s 44AA arising from derivatives (F&O) trading, ITAT held that the assessee's reliance on ICAI guidance for computing F&O turnover constituted a reasonable cause for non-maintenance of books. The Tribunal found the Income-tax Act lacks specific provisions for F&O turnover computation, accepted the assessee's detailed submissions, and determined that imposition of penalty by the Assessing Officer under s.274 was unjustified. Consequently the penalty was set aside and the assessee's appeal allowed.
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