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...
Addition u/s 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the identity, creditworthiness, and genuineness of the transaction. - The ITAT held that, in view of such facts the observations of Ld. AO cannot be rejected at threshold, in absence of submission of requisite documents pertaining to the alleged creditor by the assessee having primary onus to satisfy the Ld. AO according to the provisions of section 68, who is supporting its contentions only by producing certain internal documents and bank statements. - Therefore, the addition made by the AO under section 68 was upheld.
Addition u/s 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the identity, creditworthiness, and genuineness of the transaction. - The ITAT held that, in view of such facts the observations of Ld. AO cannot be rejected at threshold, in absence of submission of requisite documents pertaining to the alleged creditor by the assessee having primary onus to satisfy the Ld. AO according to the provisions of section 68, who is supporting its contentions only by producing certain internal documents and bank statements. - Therefore, the addition made by the AO under section 68 was upheld.
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