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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Undisclosed debit entries in the impounded books - investment in advances for properties - No such evidence furnished before the CIT(A). It is for the first time, the assessee filed such affidavit before this Tribunal, in our opinion, is only to protract the litigation. The assessee ought to have filed the same before the AO during the course of assessment proceedings in 2016 and as well before the CIT(A) in 2017. - Additions confirmed - AT
Undisclosed debit entries in the impounded books - investment in advances for properties - No such evidence furnished before the CIT(A). It is for the first time, the assessee filed such affidavit before this Tribunal, in our opinion, is only to protract the litigation. The assessee ought to have filed the same before the AO during the course of assessment proceedings in 2016 and as well before the CIT(A) in 2017. - Additions confirmed - AT
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