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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Additions towards Undisclosed profit from contract work and transport income - The tribunal found that the assumptions made by Ld. AO are without any basis, on the contrary the basis adopted by the Ld. AO was itself conflicting at places when the percentage of profit was calculated on the basis of turnover in 26AS, but have presumed that the turnover shown in 26AS was not considered by the assessee in the returned income, Ld. AO also presumed that the deemed profit u/s 44AE was not included in the profit shown by the assessee in ITR was again on the basis of presumption without any concrete evidence. - Matter restored back for fresh consideration.
Additions towards Undisclosed profit from contract work and transport income - The tribunal found that the assumptions made by Ld. AO are without any basis, on the contrary the basis adopted by the Ld. AO was itself conflicting at places when the percentage of profit was calculated on the basis of turnover in 26AS, but have presumed that the turnover shown in 26AS was not considered by the assessee in the returned income, Ld. AO also presumed that the deemed profit u/s 44AE was not included in the profit shown by the assessee in ITR was again on the basis of presumption without any concrete evidence. - Matter restored back for fresh consideration.
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