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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Validity of proceedings u/s 153C - The Tribunal upheld the proceedings u/s 153C, agreeing with the CIT(A)'s decision that the material seized during the search had a bearing on the determination of the assessee's total income, thereby justifying the assumption of jurisdiction u/s 153C. - The Tribunal concurred with the CIT(A) that the seized documents and the statements, especially when retracted, could not be solely relied upon to make additions to the assessee's income. It was emphasized that corroborative evidence was necessary to attribute the entries in the seized materials to the assessee. - The Tribunal agreed with the CIT(A)'s deletion of these additions, finding no direct reference to the assessee in the seized materials and considering the statements unreliable without independent corroborative evidence.
Validity of proceedings u/s 153C - The Tribunal upheld the proceedings u/s 153C, agreeing with the CIT(A)'s decision that the material seized during the search had a bearing on the determination of the assessee's total income, thereby justifying the assumption of jurisdiction u/s 153C. - The Tribunal concurred with the CIT(A) that the seized documents and the statements, especially when retracted, could not be solely relied upon to make additions to the assessee's income. It was emphasized that corroborative evidence was necessary to attribute the entries in the seized materials to the assessee. - The Tribunal agreed with the CIT(A)'s deletion of these additions, finding no direct reference to the assessee in the seized materials and considering the statements unreliable without independent corroborative evidence.
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