Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
ITAT held that penalty for failure to obtain tax audit was not automatic where the assessee showed reasonable cause under section 271B. The society's initial year of operations, lack of professional guidance and infrastructure, rural background, and bona fide belief that audit under the Co-operative Societies Act was sufficient were accepted, especially as the explanation was neither false nor mala fide. The nil-income assessment and absence of adverse inference of suppression supported the genuineness of the explanation. On these facts, the Tribunal found the penalty unsustainable and deleted it.
ITAT held that penalty for failure to obtain tax audit was not automatic where the assessee showed reasonable cause under section 271B. The society's initial year of operations, lack of professional guidance and infrastructure, rural background, and bona fide belief that audit under the Co-operative Societies Act was sufficient were accepted, especially as the explanation was neither false nor mala fide. The nil-income assessment and absence of adverse inference of suppression supported the genuineness of the explanation. On these facts, the Tribunal found the penalty unsustainable and deleted it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
