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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Addition u/s 69A - Addition of cash deposits made by the assessee during the demonetization period - The Tribunal examined the legality of the assessment order, the justification for the cash deposits, and the imposition of interest and penalty. It found the assessment order to be valid but disagreed with the A.O's reasoning for the cash deposit addition. The Tribunal partially allowed the appeal, reducing the addition amount based on the assessee's available cash and savings. It upheld the charging of interest but deemed the initiation of penalty proceedings premature.
Addition u/s 69A - Addition of cash deposits made by the assessee during the demonetization period - The Tribunal examined the legality of the assessment order, the justification for the cash deposits, and the imposition of interest and penalty. It found the assessment order to be valid but disagreed with the A.O's reasoning for the cash deposit addition. The Tribunal partially allowed the appeal, reducing the addition amount based on the assessee's available cash and savings. It upheld the charging of interest but deemed the initiation of penalty proceedings premature.
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