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...
Assessment u/s 153A - Addition u/s 68 - bogus LTCG - penny Stocks - whether documents found during the course of search were of incriminating nature? - The tribunal noted that the documents seized (share certificates and contract notes), alleged to be incriminating, corroborated the disclosed transactions of the purchase and sale of shares, thus not qualifying as 'incriminating evidence' discovered during the search. - The ITAT also observed that reliance on statements recorded outside the assessee's search operation, particularly from a broker, cannot augment the material found during the search to categorize it as incriminating. - Additions deleted.
Assessment u/s 153A - Addition u/s 68 - bogus LTCG - penny Stocks - whether documents found during the course of search were of incriminating nature? - The tribunal noted that the documents seized (share certificates and contract notes), alleged to be incriminating, corroborated the disclosed transactions of the purchase and sale of shares, thus not qualifying as 'incriminating evidence' discovered during the search. - The ITAT also observed that reliance on statements recorded outside the assessee's search operation, particularly from a broker, cannot augment the material found during the search to categorize it as incriminating. - Additions deleted.
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