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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Penalty for failure to comply with statutory notices was set aside because notices issued via the tax portal were not communicated and an exparte assessment under the notice scheme was passed. The assessee activated an efiling account only after the assessment order and became aware of proceedings later; the appellate authority condoned delay in filing the appeal and reopened the assessment. The tribunal found that noncommunication amounted to a reasonable cause for noncompliance and deleted the penalty. Appeal by the revenue was dismissed and penalty removed.
Penalty for failure to comply with statutory notices was set aside because notices issued via the tax portal were not communicated and an exparte assessment under the notice scheme was passed. The assessee activated an efiling account only after the assessment order and became aware of proceedings later; the appellate authority condoned delay in filing the appeal and reopened the assessment. The tribunal found that noncommunication amounted to a reasonable cause for noncompliance and deleted the penalty. Appeal by the revenue was dismissed and penalty removed.
Note: It is a system-generated summary and is for quick reference only.