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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Addition u/s 68 - bogus LTCG on shares - onus to prove - - Despite opportunities provided, the assessee company failed to adequately explain the nature and source of the funds received from the share subscriber companies. This failure to discharge the burden of proof led the A.O. to conclude that the transactions were suspicious. - The assessee company argued that it merely acted as a facilitator for transferring funds to the real beneficiary. However, this contention was not accepted by the ITAT as there was insufficient evidence to prove that the funds were indeed transferred for legitimate purposes. Argument of double taxation also not find favor of the tribunal - Additions confirmed by the tribunal.
Addition u/s 68 - bogus LTCG on shares - onus to prove - - Despite opportunities provided, the assessee company failed to adequately explain the nature and source of the funds received from the share subscriber companies. This failure to discharge the burden of proof led the A.O. to conclude that the transactions were suspicious. - The assessee company argued that it merely acted as a facilitator for transferring funds to the real beneficiary. However, this contention was not accepted by the ITAT as there was insufficient evidence to prove that the funds were indeed transferred for legitimate purposes. Argument of double taxation also not find favor of the tribunal - Additions confirmed by the tribunal.
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