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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Levy of penalty on PNB under PMLA - AT allowed the appeal in part. The Tribunal upheld findings of non-compliance with Section 12(1) read with applicable Rules but reduced certain delays and struck down an unsustainable penalty methodology. CTR delays were reduced from 151 to 38 months; penalty of ₹3,80,000 (₹10,000/month) plus ₹1,00,000 for deficient internal controls was sustained. Penalty of ₹22,40,000 imposed for delayed STRs was set aside as incorrectly calculated per report. Penalty of ₹14,57,70,000 for non-filing of NTRs (₹10,000 per transaction) was upheld; the additional ₹1,00,000 internal-control penalty was dispensed with. Penalty of ₹27,00,000 for delayed CBWTRs was affirmed; repetitive internal-control penalty dispensed. Penalty under Section 12A was sustained.
Levy of penalty on PNB under PMLA - AT allowed the appeal in part. The Tribunal upheld findings of non-compliance with Section 12(1) read with applicable Rules but reduced certain delays and struck down an unsustainable penalty methodology. CTR delays were reduced from 151 to 38 months; penalty of ₹3,80,000 (₹10,000/month) plus ₹1,00,000 for deficient internal controls was sustained. Penalty of ₹22,40,000 imposed for delayed STRs was set aside as incorrectly calculated per report. Penalty of ₹14,57,70,000 for non-filing of NTRs (₹10,000 per transaction) was upheld; the additional ₹1,00,000 internal-control penalty was dispensed with. Penalty of ₹27,00,000 for delayed CBWTRs was affirmed; repetitive internal-control penalty dispensed. Penalty under Section 12A was sustained.
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