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 of the non-resident assessee and deleted the penalty imposed u/s 272A(1)(d) for alleged non-compliance with notice u/s 142(1). The Tribunal noted that the assessee, a resident of the United Kingdom with no income source in India for the relevant year, had not filed a return u/s 139. It found no evidence on record that the notice u/s 142(1), dated 06.01.2023, was ever served on the assessee, stressing that the statute requires valid service, not mere issuance. As the assessment was completed ex parte, the ITAT accepted that the assessee was unaware of the proceedings and held the penalty unsustainable.
The ITAT allowed the appeal of the non-resident assessee and deleted the penalty imposed u/s 272A(1)(d) for alleged non-compliance with notice u/s 142(1). The Tribunal noted that the assessee, a resident of the United Kingdom with no income source in India for the relevant year, had not filed a return u/s 139. It found no evidence on record that the notice u/s 142(1), dated 06.01.2023, was ever served on the assessee, stressing that the statute requires valid service, not mere issuance. As the assessment was completed ex parte, the ITAT accepted that the assessee was unaware of the proceedings and held the penalty unsustainable.
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