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 allowed the appeal and deleted the penalty imposed under s. 271(1)(c) on the assessee, holding that the AO erred by attributing joint-account cash deposits solely to the assessee without verifying receipts by other joint-account holders or confining additions to the extent of income declared by the assessee or deposits attributable to him. The Tribunal found the AO failed to make requisite enquiries into family-member deposits and proceeded to levy penalty without proper basis. The Tribunal also noted procedural prejudice: notices were not received by the assessee due to communications sent to an incorrect email ID. On these grounds the penalty was held unjustified and set aside.
ITAT allowed the appeal and deleted the penalty imposed under s. 271(1)(c) on the assessee, holding that the AO erred by attributing joint-account cash deposits solely to the assessee without verifying receipts by other joint-account holders or confining additions to the extent of income declared by the assessee or deposits attributable to him. The Tribunal found the AO failed to make requisite enquiries into family-member deposits and proceeded to levy penalty without proper basis. The Tribunal also noted procedural prejudice: notices were not received by the assessee due to communications sent to an incorrect email ID. On these grounds the penalty was held unjustified and set aside.
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