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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Penalty under s. 272A(1)(d) for alleged non-compliance with notices issued under s. 142(1) was examined where the notices were only uploaded on the e-filing portal and the assessment was completed ex parte under s. 144. Since there was no evidence of effective service or actual communication of the notices, the assessee's lack of actual knowledge constituted "reasonable cause" for non-compliance, and penalty could not be sustained merely because notices remained on the portal. Consequently, the appellate order affirming the penalty was set aside and the penalty was deleted. - ITAT
Penalty under s. 272A(1)(d) for alleged non-compliance with notices issued under s. 142(1) was examined where the notices were only uploaded on the e-filing portal and the assessment was completed ex parte under s. 144. Since there was no evidence of effective service or actual communication of the notices, the assessee's lack of actual knowledge constituted "reasonable cause" for non-compliance, and penalty could not be sustained merely because notices remained on the portal. Consequently, the appellate order affirming the penalty was set aside and the penalty was deleted. - ITAT
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