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 68 r.w.s. 115BBE - assessment framed u/s 143(3) - amount being inheritance from his father by way of will - Burden to prove - where the assessee has disclosed primary facts then the burden shifts to the Revenue. In the instant case also the assessee has filed all the necessary evidences before the authorities below. However, no further investigation was carried out - once identity of the person giving the money is established and other evidences are placed before the AO pointing that entry is not fictitious then initial burden lying on the assessee can be said to be fully discharged. - AT
Addition u/s 68 r.w.s. 115BBE - assessment framed u/s 143(3) - amount being inheritance from his father by way of will - Burden to prove - where the assessee has disclosed primary facts then the burden shifts to the Revenue. In the instant case also the assessee has filed all the necessary evidences before the authorities below. However, no further investigation was carried out - once identity of the person giving the money is established and other evidences are placed before the AO pointing that entry is not fictitious then initial burden lying on the assessee can be said to be fully discharged. - AT
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