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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The ITAT concluded that the addition made by the AO was not justified. They noted that the assessee had reconciled the differences in stock with supporting evidence, and neither the AO nor the CIT(A) had pointed out any defects or discrepancies in the reconciliation. - The Tribunal held that mere existence of differences in stock during a survey does not warrant automatic additions if the assessee has reconciled the differences with supporting evidence.
Excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The ITAT concluded that the addition made by the AO was not justified. They noted that the assessee had reconciled the differences in stock with supporting evidence, and neither the AO nor the CIT(A) had pointed out any defects or discrepancies in the reconciliation. - The Tribunal held that mere existence of differences in stock during a survey does not warrant automatic additions if the assessee has reconciled the differences with supporting evidence.
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