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 assessee's appeal and deleted penalty imposed u/s 271D for alleged violation of s. 269SS. The Tribunal found the impugned cash receipt formed part of the genuine sale consideration for land, was duly recorded in the books, immediately deposited in the bank, and fully disclosed to the tax authorities. There was no finding in the assessment or penalty orders that the transaction was not bona fide or that it was structured to evade tax. Holding that the cash was accepted under compulsion of the buyer at the time of registration, ITAT treated these circumstances as "reasonable cause" u/s 273B and held that penalty u/s 271D was not leviable.
ITAT allowed the assessee's appeal and deleted penalty imposed u/s 271D for alleged violation of s. 269SS. The Tribunal found the impugned cash receipt formed part of the genuine sale consideration for land, was duly recorded in the books, immediately deposited in the bank, and fully disclosed to the tax authorities. There was no finding in the assessment or penalty orders that the transaction was not bona fide or that it was structured to evade tax. Holding that the cash was accepted under compulsion of the buyer at the time of registration, ITAT treated these circumstances as "reasonable cause" u/s 273B and held that penalty u/s 271D was not leviable.
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