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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Inflation in expenses or bogus/inflated purchases - Since, the printouts of the hard disc clearly mentioned that "forecast" and since, the Assessing Officer in the two preceding assessment years has accepted the reply of the assessee and no addition has been made in the order passed under section 143(3) of the Act, therefore, following the rule of consistency, no addition can be made for the impugned assessment year, especially when no other corroborative evidence such as bogus purchases bills/bogus expenses or unexplained investment, etc., were found during the course of search. - AT
Inflation in expenses or bogus/inflated purchases - Since, the printouts of the hard disc clearly mentioned that "forecast" and since, the Assessing Officer in the two preceding assessment years has accepted the reply of the assessee and no addition has been made in the order passed under section 143(3) of the Act, therefore, following the rule of consistency, no addition can be made for the impugned assessment year, especially when no other corroborative evidence such as bogus purchases bills/bogus expenses or unexplained investment, etc., were found during the course of search. - AT
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