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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Additions based on 26AS statement - undisclosed income - Petitioner has not made any complaint at any stage regarding any fictitious or wrong entries in the 26AS statement reflecting tax deduction at source against receipt of payments from these three concerns. It further appears that the assessing officer had undertaken inquiries from these three concerns who confirmed the payments made to the petitioner during the financial year 2010-11. Since the petitioner's books of account were not maintained or audited and the receipts were not only confirmed by the three concerns as above, but 26AS statement and Form-16A submitted by them revealed undisclosed income - Additions confirmed - HC
Additions based on 26AS statement - undisclosed income - Petitioner has not made any complaint at any stage regarding any fictitious or wrong entries in the 26AS statement reflecting tax deduction at source against receipt of payments from these three concerns. It further appears that the assessing officer had undertaken inquiries from these three concerns who confirmed the payments made to the petitioner during the financial year 2010-11. Since the petitioner's books of account were not maintained or audited and the receipts were not only confirmed by the three concerns as above, but 26AS statement and Form-16A submitted by them revealed undisclosed income - Additions confirmed - HC
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