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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Unexplained money u/s 69A r.w.s. 115BBE - Cash seized in search - The assessee provided a cash reconciliation statement, demonstrating that the cash balance remained consistent after the inter-branch transfer. The statement showed that the cash was transferred from the Kolkata branch to the Gurgaon branch, with corresponding entries in the cash books of both branches. Additionally, the cash transferred was recorded in the books with a slight delay, but the company as a whole maintained sufficient cash balance to explain the seized amount. - ITAT deleted the additions.
Unexplained money u/s 69A r.w.s. 115BBE - Cash seized in search - The assessee provided a cash reconciliation statement, demonstrating that the cash balance remained consistent after the inter-branch transfer. The statement showed that the cash was transferred from the Kolkata branch to the Gurgaon branch, with corresponding entries in the cash books of both branches. Additionally, the cash transferred was recorded in the books with a slight delay, but the company as a whole maintained sufficient cash balance to explain the seized amount. - ITAT deleted the additions.
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