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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The ITAT upholds the CIT(A)'s deletion of the penalty under section 271(1)(c) imposed on the assessee for alleged furnishing of inaccurate particulars of income. The Tribunal accepts that the assessee, in liquidation, could not file a timely appeal against the assessment order and that the AO's disagreement with the assessee's bad-debt claim and its evidentiary shortcomings did not, per controlling authorities, automatically attract penalty. On that basis the Tribunal affirms that imposition of the penalty was unsustainable and dismisses the revenue's appeal, thereby restoring the CIT(A)'s order deleting the penalty.
The ITAT upholds the CIT(A)'s deletion of the penalty under section 271(1)(c) imposed on the assessee for alleged furnishing of inaccurate particulars of income. The Tribunal accepts that the assessee, in liquidation, could not file a timely appeal against the assessment order and that the AO's disagreement with the assessee's bad-debt claim and its evidentiary shortcomings did not, per controlling authorities, automatically attract penalty. On that basis the Tribunal affirms that imposition of the penalty was unsustainable and dismisses the revenue's appeal, thereby restoring the CIT(A)'s order deleting the penalty.
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