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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Reopening of assessment u/s 147 - addition as concealed income u/s. 69 - The fact that the assessee has consistently alleged connivance of the bank authorities coupled with the fact that the currency details and lack of PAN details of the depositor evident on record remain unrebutted on record by the tax authorities cannot be allowed to remain ignored. In the facts as they stand unless these assertions are rebutted by cogent evidence, the assessee appears to have a claim which cannot be easily discarded - Matter remitted back for fresh adjudication - AT
Reopening of assessment u/s 147 - addition as concealed income u/s. 69 - The fact that the assessee has consistently alleged connivance of the bank authorities coupled with the fact that the currency details and lack of PAN details of the depositor evident on record remain unrebutted on record by the tax authorities cannot be allowed to remain ignored. In the facts as they stand unless these assertions are rebutted by cogent evidence, the assessee appears to have a claim which cannot be easily discarded - Matter remitted back for fresh adjudication - AT
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