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 addressed penalty under the Income-tax regime where an assessee, during search proceedings, admitted undisclosed income, explained the manner and source of accrual, and included the disclosure in the return with taxes and interest paid; the assessing officer and appellate authority acknowledged the disclosure. Applying the principle that a voluntary, explained disclosure during search accepted by revenue officers and regularised by return and tax payment negates penal liability, the tribunal found the statutory criteria satisfied and set aside the penalty, allowing the appeal.
ITAT addressed penalty under the Income-tax regime where an assessee, during search proceedings, admitted undisclosed income, explained the manner and source of accrual, and included the disclosure in the return with taxes and interest paid; the assessing officer and appellate authority acknowledged the disclosure. Applying the principle that a voluntary, explained disclosure during search accepted by revenue officers and regularised by return and tax payment negates penal liability, the tribunal found the statutory criteria satisfied and set aside the penalty, allowing the appeal.
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