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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Estimating the income of the assessee @ 8% on the sub-contract turnover - On verifying the paper book of the assessee running to 32 pages, we do not find any concrete evidence to establish that the assessee is actually executing any civil contract works with respect to the contracts he has claimed to have undertaken - assessee could also not furnish proper evidence to establish that the parties from whom the assessee had received the amount of ₹ 18 lakhs is genuine. - Additions made by AO sustained - AT
Estimating the income of the assessee @ 8% on the sub-contract turnover - On verifying the paper book of the assessee running to 32 pages, we do not find any concrete evidence to establish that the assessee is actually executing any civil contract works with respect to the contracts he has claimed to have undertaken - assessee could also not furnish proper evidence to establish that the parties from whom the assessee had received the amount of ₹ 18 lakhs is genuine. - Additions made by AO sustained - AT
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