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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Additions towards the alleged unaccounted sales - The AT noted that the addition had been deleted by the ld. CIT(A), and since there was no appeal from the Revenue, this issue was resolved in favor of the assessee. Concerning the stock difference, it was observed that the gross profit until the survey date was already included in the gross profit for the entire financial year, thus making any additional addition redundant and amounting to double counting. Consequently, the AT directed the Assessing Officer to delete the addition.
Additions towards the alleged unaccounted sales - The AT noted that the addition had been deleted by the ld. CIT(A), and since there was no appeal from the Revenue, this issue was resolved in favor of the assessee. Concerning the stock difference, it was observed that the gross profit until the survey date was already included in the gross profit for the entire financial year, thus making any additional addition redundant and amounting to double counting. Consequently, the AT directed the Assessing Officer to delete the addition.
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