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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Addition u/s 69B - Cash transactions in the seized documents during a search operation - cash against sale of flat - When no material has been found that assessee has made any booking for the flat, a mere entry in a pen drive of a third party cannot ipso facto fasten the liability of on money transaction upon the assessee without further corroborative material brought on record. As a matter of fact as noted by the learned CIT(A) the other materials further support the view that the addition in the hands of the assessee is not sustainable in as much as there was a booking of flat by the assessee’s wife with the same developer which was duly cancelled and booking was refunded prior to the entry of on money cash transaction. - AT
Addition u/s 69B - Cash transactions in the seized documents during a search operation - cash against sale of flat - When no material has been found that assessee has made any booking for the flat, a mere entry in a pen drive of a third party cannot ipso facto fasten the liability of on money transaction upon the assessee without further corroborative material brought on record. As a matter of fact as noted by the learned CIT(A) the other materials further support the view that the addition in the hands of the assessee is not sustainable in as much as there was a booking of flat by the assessee’s wife with the same developer which was duly cancelled and booking was refunded prior to the entry of on money cash transaction. - AT
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