Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
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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