Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
