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 based on voluntary disclosure made by the key person of the assesse group during the course of search which has subsequently been retracted - The statement recorded u/s 132(4) - The Tribunal observed that admissions made under duress or misconception can be retracted. The reliance solely on such statements for making additions, without corroborative evidence, is not sustainable. - The Tribunal held that without any incriminating material specifically linking the income to undisclosed sources, the disclosed income should be treated as business income, not taxable u/s 115BBE.
Addition based on voluntary disclosure made by the key person of the assesse group during the course of search which has subsequently been retracted - The statement recorded u/s 132(4) - The Tribunal observed that admissions made under duress or misconception can be retracted. The reliance solely on such statements for making additions, without corroborative evidence, is not sustainable. - The Tribunal held that without any incriminating material specifically linking the income to undisclosed sources, the disclosed income should be treated as business income, not taxable u/s 115BBE.
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