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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Unaccounted income disclosed during the course of survey - In the present case, not only one partner of the assessee made discloser of additional undisclosed income, but it was endorsed by two other partners in presence of their CA. - During first appellate stage the assessee try to introduce new facts that the undisclosed additional income was earned from the business of sarees and dress material for which no separate accounts were maintained. - If the mistake was realised later on the statement should have been retracted immediately. - Additions confirmed - AT
Unaccounted income disclosed during the course of survey - In the present case, not only one partner of the assessee made discloser of additional undisclosed income, but it was endorsed by two other partners in presence of their CA. - During first appellate stage the assessee try to introduce new facts that the undisclosed additional income was earned from the business of sarees and dress material for which no separate accounts were maintained. - If the mistake was realised later on the statement should have been retracted immediately. - Additions confirmed - AT
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