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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Unexplained cash credits u/s 68 - Interest expenditure debited as interest on securities - allegation of involvement in multi crore securities transactions scam of nineties infamously known as Harshad Mehta Scam, Assessee got labelled as party under the Special Court's (TORTS) Act, 1992 - The ITAT examined each addition separately, considering the evidence and explanations provided by the assessee. It concluded that the additions were not justified due to satisfactory explanations and evidence presented by the assessee. - The High Court dismissed the appeal, finding no merit in the revenue's contentions.
Unexplained cash credits u/s 68 - Interest expenditure debited as interest on securities - allegation of involvement in multi crore securities transactions scam of nineties infamously known as Harshad Mehta Scam, Assessee got labelled as party under the Special Court's (TORTS) Act, 1992 - The ITAT examined each addition separately, considering the evidence and explanations provided by the assessee. It concluded that the additions were not justified due to satisfactory explanations and evidence presented by the assessee. - The High Court dismissed the appeal, finding no merit in the revenue's contentions.
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