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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Unexplained credit in the capital account - Impugned order shows that in spite of repeated notices issued, except seeking adjournment, the assessee did not cooperate with the first appellate authority nor any attempt was made to produce the information that was sought by the AO. Even before us also, the assessee is not diligent to prosecute this appeal. For want of evidence or material supporting the claims of the assessee, it is not possible for us to take a different view that was taken by the authorities. - AT
Unexplained credit in the capital account - Impugned order shows that in spite of repeated notices issued, except seeking adjournment, the assessee did not cooperate with the first appellate authority nor any attempt was made to produce the information that was sought by the AO. Even before us also, the assessee is not diligent to prosecute this appeal. For want of evidence or material supporting the claims of the assessee, it is not possible for us to take a different view that was taken by the authorities. - AT
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