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...
Addition of unexplained/unsecured loans/cash credit - All the transactions have passed through the eyes of the auditor who has issued tax audit report u/s 44AB of the Act mentioning about the loans taken and repaid during the year. There is no evidence on record to shows that any enquiry was initiated by the assessing officer on the basis of PAN No. and other details. - CIT(A) rightly deleted the additions.
Addition of unexplained/unsecured loans/cash credit - All the transactions have passed through the eyes of the auditor who has issued tax audit report u/s 44AB of the Act mentioning about the loans taken and repaid during the year. There is no evidence on record to shows that any enquiry was initiated by the assessing officer on the basis of PAN No. and other details. - CIT(A) rightly deleted the additions.
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