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 set aside the penalty imposed under section 271F. The Tribunal accepted the assessee's plea that failure to file the return under section 139(1) for the relevant assessment year was due to reasonable cause within the meaning of section 273B, namely that the assessee was wholly occupied assisting a close family member through acute legal and emotional distress coinciding with the filing deadline. Noting the absence of appellate concurrence by the CIT(A.) on the point of reasonable cause and considering the facts, ITAT held the levy by the AO and confirmation by the CIT(A.) unjustified and deleted the penalty; Ground No.1 allowed.
ITAT allowed the appeal and set aside the penalty imposed under section 271F. The Tribunal accepted the assessee's plea that failure to file the return under section 139(1) for the relevant assessment year was due to reasonable cause within the meaning of section 273B, namely that the assessee was wholly occupied assisting a close family member through acute legal and emotional distress coinciding with the filing deadline. Noting the absence of appellate concurrence by the CIT(A.) on the point of reasonable cause and considering the facts, ITAT held the levy by the AO and confirmation by the CIT(A.) unjustified and deleted the penalty; Ground No.1 allowed.
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