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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ITAT upheld penalty under section 270A for under-reporting in consequence of misreporting, holding that the assessee's deduction claim for a political donation was based on a non-genuine transaction exposed through investigation. The later withdrawal of the claim in response to notice under section 148 was not voluntary but a post-detection attempt to reduce consequences, so it did not cure the initial misrepresentation. The Tribunal also rejected the challenge to the penalty notice, finding that the specific statutory limb under section 270A(9)(a) had been clearly invoked and the assessee was aware of the precise allegation. The appeal was dismissed.
ITAT upheld penalty under section 270A for under-reporting in consequence of misreporting, holding that the assessee's deduction claim for a political donation was based on a non-genuine transaction exposed through investigation. The later withdrawal of the claim in response to notice under section 148 was not voluntary but a post-detection attempt to reduce consequences, so it did not cure the initial misrepresentation. The Tribunal also rejected the challenge to the penalty notice, finding that the specific statutory limb under section 270A(9)(a) had been clearly invoked and the assessee was aware of the precise allegation. The appeal was dismissed.
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