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...
Issue concerns imposition of penalty for non compliance with statutory notices and the availability of reasonable cause under the tax statute. Tribunal applied the requirement that reasonable cause be supported by contemporaneous evidence and found the medical certificate dated after the relevant notices insufficient; evidence of substantial online income and repeated failure to respond during assessment and penalty proceedings indicated casual indifference. On these grounds the Tribunal upheld the penalty for non compliance, rejecting the reasonable cause plea and confirming the penalty order for the assessment year specified.
Issue concerns imposition of penalty for non compliance with statutory notices and the availability of reasonable cause under the tax statute. Tribunal applied the requirement that reasonable cause be supported by contemporaneous evidence and found the medical certificate dated after the relevant notices insufficient; evidence of substantial online income and repeated failure to respond during assessment and penalty proceedings indicated casual indifference. On these grounds the Tribunal upheld the penalty for non compliance, rejecting the reasonable cause plea and confirming the penalty order for the assessment year specified.
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