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 - Bogus LTCG - Penny stock transactions - The Tribunal found that the assessee had provided sufficient documentary evidence supporting the genuineness of the transactions, including purchase and sale of shares through the Bombay Stock Exchange (BSE), payment through banking channels, and compliance with regulatory requirements (like STT). - ITAT noted that the AO primarily relied on a general report by the Kolkata Investigation wing and failed to connect the assessee or their transactions directly to any alleged manipulation of share prices. Additionally, SEBI did not find any wrongdoing on the part of the assessee or their broker. - Given the genuineness of the LTCG transactions was established, the Tribunal agreed with the CIT(A)'s decision to delete the addition.
Addition u/s 68 - Bogus LTCG - Penny stock transactions - The Tribunal found that the assessee had provided sufficient documentary evidence supporting the genuineness of the transactions, including purchase and sale of shares through the Bombay Stock Exchange (BSE), payment through banking channels, and compliance with regulatory requirements (like STT). - ITAT noted that the AO primarily relied on a general report by the Kolkata Investigation wing and failed to connect the assessee or their transactions directly to any alleged manipulation of share prices. Additionally, SEBI did not find any wrongdoing on the part of the assessee or their broker. - Given the genuineness of the LTCG transactions was established, the Tribunal agreed with the CIT(A)'s decision to delete the addition.
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