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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Penalty under section 272A(1)(d) for non-compliance with a statutory notice was deleted by the ITAT. The Tribunal noted that the quantum assessment had already been restored to the Assessing Officer for de novo consideration and, although that restoration did not directly determine the non-appearance issue, it considered the assessee's consistent follow-up with the tax authorities in other matters. On that overall conduct and in the interests of justice, the Tribunal directed deletion of the penalty and allowed the appeal.
Penalty under section 272A(1)(d) for non-compliance with a statutory notice was deleted by the ITAT. The Tribunal noted that the quantum assessment had already been restored to the Assessing Officer for de novo consideration and, although that restoration did not directly determine the non-appearance issue, it considered the assessee's consistent follow-up with the tax authorities in other matters. On that overall conduct and in the interests of justice, the Tribunal directed deletion of the penalty and allowed the appeal.
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