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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Rejection of the books of accounts - best judgment assessment u/s 144 - addition of the sales made in cash on account of unexplained cash credit u/s 68 - While the rejection of books of accounts was upheld, the tribunal disagreed with the addition of unexplained cash credit under section 68, emphasizing the necessity for a fair and scientific estimation of income. They directed the Assessing Officer to delete the addition made under section 68, highlighting inconsistencies in the assessment process.
Rejection of the books of accounts - best judgment assessment u/s 144 - addition of the sales made in cash on account of unexplained cash credit u/s 68 - While the rejection of books of accounts was upheld, the tribunal disagreed with the addition of unexplained cash credit under section 68, emphasizing the necessity for a fair and scientific estimation of income. They directed the Assessing Officer to delete the addition made under section 68, highlighting inconsistencies in the assessment process.
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