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 - unexplained credit/receipt - bogus receipt towards share capital and share premium - The suspicion entertained on bona fides has not been carried out to any logical end. AO has attempted to implicate the assessee mainly on two grounds namely, inspector report which shows that the assessee was not in existence at the address and secondly, the summons issued u/s 131 has not been complied with by the Director of the Assessee. Both the points do not have much force. - AT
Addition u/s 68 - unexplained credit/receipt - bogus receipt towards share capital and share premium - The suspicion entertained on bona fides has not been carried out to any logical end. AO has attempted to implicate the assessee mainly on two grounds namely, inspector report which shows that the assessee was not in existence at the address and secondly, the summons issued u/s 131 has not been complied with by the Director of the Assessee. Both the points do not have much force. - AT
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