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 affirmed the quantum disallowance of unpaid leave encashment under the governing statutory framework, but allowed the appeal against imposition of penalty under section 271(1)(c). The Tribunal held the deduction claim was governed by section 43B(f) and upheld the CIT(A)'s disallowance in the quantum proceedings; however, it found no concealment or furnishing of inaccurate particulars warranting penalty, noting the assessee had disclosed the amount in audited accounts, relied on prevailing judicial views then favorable to the assessee, and acted bona fide while litigation was pending before the SC. The ITAT set aside the impugned appellate order and directed the AO to delete the penalty.
ITAT affirmed the quantum disallowance of unpaid leave encashment under the governing statutory framework, but allowed the appeal against imposition of penalty under section 271(1)(c). The Tribunal held the deduction claim was governed by section 43B(f) and upheld the CIT(A)'s disallowance in the quantum proceedings; however, it found no concealment or furnishing of inaccurate particulars warranting penalty, noting the assessee had disclosed the amount in audited accounts, relied on prevailing judicial views then favorable to the assessee, and acted bona fide while litigation was pending before the SC. The ITAT set aside the impugned appellate order and directed the AO to delete the penalty.
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