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 allowed the appeal and set aside the penalty under s.271F of the Act (Rs.5,000) imposed for non-filing of the original return under s.139(1). The Tribunal found the assessee to be a non-resident, the USD 1,200,000 transaction to be a foreign loan for US business properly evidenced by US bank records and a promissory note, and no part of the sum was remitted to or utilized in India. The transaction had been substantively examined in the assessment of another person and the addition in the present case was protective. Applying s.273B, the ITAT held there was reasonable cause and bona fide belief; therefore the penalty was unsustainable and deleted.
The ITAT allowed the appeal and set aside the penalty under s.271F of the Act (Rs.5,000) imposed for non-filing of the original return under s.139(1). The Tribunal found the assessee to be a non-resident, the USD 1,200,000 transaction to be a foreign loan for US business properly evidenced by US bank records and a promissory note, and no part of the sum was remitted to or utilized in India. The transaction had been substantively examined in the assessment of another person and the addition in the present case was protective. Applying s.273B, the ITAT held there was reasonable cause and bona fide belief; therefore the penalty was unsustainable and deleted.
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