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 assessee's appeal and set aside the penalty under s.271D imposed for alleged default under s.269SS. The Tribunal found on the facts that the assessee was not the landowner when advances were received, had filed agreements with the AO evidencing proposed purchases, and the transactions ultimately did not materialize; the amounts were refunded to prospective buyers by allotment of shares on 31.03.2011 after the vendor failed to perform. Applying the amended scope of s.269SS and following relevant authorities, the Tribunal held s.269SS inapplicable and consequently cancelled the penalty confirmed by the CIT(A), allowing the assessee's appeal.
The ITAT allowed the assessee's appeal and set aside the penalty under s.271D imposed for alleged default under s.269SS. The Tribunal found on the facts that the assessee was not the landowner when advances were received, had filed agreements with the AO evidencing proposed purchases, and the transactions ultimately did not materialize; the amounts were refunded to prospective buyers by allotment of shares on 31.03.2011 after the vendor failed to perform. Applying the amended scope of s.269SS and following relevant authorities, the Tribunal held s.269SS inapplicable and consequently cancelled the penalty confirmed by the CIT(A), allowing the assessee's appeal.
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