Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Delayed furnishing of a statement of financial transactions may attract penalty, but belated filing alone does not exclude the statutory defence of reasonable cause. Penalty should not be sustained without examining the taxpayer's explanation and supporting evidence for the delay. Where the first appellate authority has dismissed the matter without deciding the grounds on merits or considering reasonable cause, it should provide due opportunity, examine that defence, and determine the penalty afresh in accordance with law.
Delayed furnishing of a statement of financial transactions may attract penalty, but belated filing alone does not exclude the statutory defence of reasonable cause. Penalty should not be sustained without examining the taxpayer's explanation and supporting evidence for the delay. Where the first appellate authority has dismissed the matter without deciding the grounds on merits or considering reasonable cause, it should provide due opportunity, examine that defence, and determine the penalty afresh in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
