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 of cash salary u/s 69C - Assessee argued that proposed cash was also found during the course of first search and therefore, cannot be put to use for making assessment consequent to the second search and even otherwise, according to the appellant, the document is dumb as it clearly states that the salary was only proposed and never paid - this expenditure cannot be added as income from undisclosed sources and therefore, no addition can be made. - AT
Addition of cash salary u/s 69C - Assessee argued that proposed cash was also found during the course of first search and therefore, cannot be put to use for making assessment consequent to the second search and even otherwise, according to the appellant, the document is dumb as it clearly states that the salary was only proposed and never paid - this expenditure cannot be added as income from undisclosed sources and therefore, no addition can be made. - AT
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