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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Addition based on entries appearing in a diary seized from the assessee - Penalty proceedings u/s. 269SS, 269T and 271AAB - The CIT(A) held that the AO's findings were not sustainable as they lacked material evidence and reasoning. The CIT(A) noted that the transactions in the seized diary were related to the partnership firms' projects, and the assessee was maintaining accounts for the partners of these firms. The CIT(A) also considered the disclosure made by the partnership firms while deciding the penalty. - The ITAT dismissed the appeal filed by the Revenue, affirming the CIT(A)'s order.
Addition based on entries appearing in a diary seized from the assessee - Penalty proceedings u/s. 269SS, 269T and 271AAB - The CIT(A) held that the AO's findings were not sustainable as they lacked material evidence and reasoning. The CIT(A) noted that the transactions in the seized diary were related to the partnership firms' projects, and the assessee was maintaining accounts for the partners of these firms. The CIT(A) also considered the disclosure made by the partnership firms while deciding the penalty. - The ITAT dismissed the appeal filed by the Revenue, affirming the CIT(A)'s order.
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