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 - maturity proceeds of FDRs, alleging unexplained cash credits - In this regard, assessee submits a copy of the bank certificates issued by the Dena Bank evidencing the fact that the said FDRs were not made during the current year but were made in the earlier years. Since the investments in the FDRs were not made during the year under consideration, the question of taxing the same alleging it as unexplained cash credit does not arise and hence, based on this factual position we delete the addition. - AT
Addition u/s 68 - maturity proceeds of FDRs, alleging unexplained cash credits - In this regard, assessee submits a copy of the bank certificates issued by the Dena Bank evidencing the fact that the said FDRs were not made during the current year but were made in the earlier years. Since the investments in the FDRs were not made during the year under consideration, the question of taxing the same alleging it as unexplained cash credit does not arise and hence, based on this factual position we delete the addition. - AT
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