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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Unexplained cash deposit in the NRO bank account - Additions u/s 69 - once the assessee has provided an explanation which in the instant case, we find reasonable and plausible, the deposit so made cannot remain unexplained. In view of the same, we find that even though the assessee has failed to bring on record any evidence issued by Thomas Cook in support of exchange of foreign currency with Indian Rupees,there is no basis for invoking the provisions of section 69 in the instant case
Unexplained cash deposit in the NRO bank account - Additions u/s 69 - once the assessee has provided an explanation which in the instant case, we find reasonable and plausible, the deposit so made cannot remain unexplained. In view of the same, we find that even though the assessee has failed to bring on record any evidence issued by Thomas Cook in support of exchange of foreign currency with Indian Rupees,there is no basis for invoking the provisions of section 69 in the instant case
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