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 u/s 68 in respect of jewellery - It is not in dispute that what is received as gift is only jewellery. Hence, what is received is only gift in kind. Accordingly, the provisions of Section 68 per se could not be invoked in the instant case. It is trite law and the bare reading of the provisions of Section 68 are very clear that the said provisions could be made applicable only for sums received in cash or cheque or demand draft for which satisfactory explanation could not be given by the assessee. - AT
Addition u/s 68 in respect of jewellery - It is not in dispute that what is received as gift is only jewellery. Hence, what is received is only gift in kind. Accordingly, the provisions of Section 68 per se could not be invoked in the instant case. It is trite law and the bare reading of the provisions of Section 68 are very clear that the said provisions could be made applicable only for sums received in cash or cheque or demand draft for which satisfactory explanation could not be given by the assessee. - AT
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