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 272A(1)(d) for alleged non-compliance with a notice under section 142(1); it found that the assessee, a farmer represented through an advocate, did not receive communications due to non-payment of advocate fees and absence of physical service, constituting a reasonable cause under the statutory exception, and the Revenue conceded non-service. The consequence is deletion of the Rs. 10,000 penalty levied under 272A(1)(d), deciding in favour of the assessee.
ITAT addressed penalty under 272A(1)(d) for alleged non-compliance with a notice under section 142(1); it found that the assessee, a farmer represented through an advocate, did not receive communications due to non-payment of advocate fees and absence of physical service, constituting a reasonable cause under the statutory exception, and the Revenue conceded non-service. The consequence is deletion of the Rs. 10,000 penalty levied under 272A(1)(d), deciding in favour of the assessee.
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