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 for furnishing inaccurate particulars was upheld where commission expenditure was found non-genuine, as third-party verification showed the alleged intermediaries had not rendered services and the assessee failed to substantiate the claim. Where penalty had been computed on additions not finally sustained in appeal, it was treated as a mistake apparent from the record and was directed to be recomputed only on the surviving addition. Penalty under section 41(1) for waiver of interest liability was deleted for one year because the assessee's explanation based on a bona fide one-time settlement with banks was accepted, and penalty was not automatic merely because the addition survived.
Penalty for furnishing inaccurate particulars was upheld where commission expenditure was found non-genuine, as third-party verification showed the alleged intermediaries had not rendered services and the assessee failed to substantiate the claim. Where penalty had been computed on additions not finally sustained in appeal, it was treated as a mistake apparent from the record and was directed to be recomputed only on the surviving addition. Penalty under section 41(1) for waiver of interest liability was deleted for one year because the assessee's explanation based on a bona fide one-time settlement with banks was accepted, and penalty was not automatic merely because the addition survived.
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