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 held that repeated non-compliances of multiple notices issued u/s 142(1) on the same subject constitute a single default for purposes of penalty u/s 271(1)(b). Accepting the assessee's plea, the Tribunal ruled that successive notices seeking identical information do not multiply the default. Applying s. 273B, it upheld penalty only for the first non-compliance and deleted penalty for the remaining four instances. The penalty was thus restricted to Rs. 10,000 for one default instead of five, and the assessee's appeal was partly allowed.
ITAT held that repeated non-compliances of multiple notices issued u/s 142(1) on the same subject constitute a single default for purposes of penalty u/s 271(1)(b). Accepting the assessee's plea, the Tribunal ruled that successive notices seeking identical information do not multiply the default. Applying s. 273B, it upheld penalty only for the first non-compliance and deleted penalty for the remaining four instances. The penalty was thus restricted to Rs. 10,000 for one default instead of five, and the assessee's appeal was partly allowed.
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