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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Penalty under section 270A could not be sustained where the assessee had filed Form No. 68 seeking immunity under section 270AA(2) and the Revenue failed to show that the application had been decided. The ITAT restored the matter to the Assessing Officer to first dispose of the immunity request in accordance with law; only if immunity is rejected may penalty proceedings be initiated afresh. For the later year, where immunity under section 270AA(4) had already been granted, the subsequent penalty order was held unsustainable and was set aside.
Penalty under section 270A could not be sustained where the assessee had filed Form No. 68 seeking immunity under section 270AA(2) and the Revenue failed to show that the application had been decided. The ITAT restored the matter to the Assessing Officer to first dispose of the immunity request in accordance with law; only if immunity is rejected may penalty proceedings be initiated afresh. For the later year, where immunity under section 270AA(4) had already been granted, the subsequent penalty order was held unsustainable and was set aside.
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