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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Addition made u/s. 68 - Addition of agricultural income - admission of additional evidences - There should not be any dispute that the admission of additional evidences filed in support of the claim made in the return of income would promote the cause of justice. Accordingly, admit the additional evidences furnished by the assessee. Since both the issues required to be examined afresh duly considering the additional evidences furnished by the assessee,we set aside the order passed by Ld. CIT(A) on both the issues and restore them to the file of AO for examining them afresh. - AT
Addition made u/s. 68 - Addition of agricultural income - admission of additional evidences - There should not be any dispute that the admission of additional evidences filed in support of the claim made in the return of income would promote the cause of justice. Accordingly, admit the additional evidences furnished by the assessee. Since both the issues required to be examined afresh duly considering the additional evidences furnished by the assessee,we set aside the order passed by Ld. CIT(A) on both the issues and restore them to the file of AO for examining them afresh. - AT
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