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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Reopening of assessment u/s 147/148 - reasons to believe - The Tribunal upheld the validity of the reopening, considering the reasons recorded by the Assessing Officer as based on tangible material. While the assessee failed to provide satisfactory evidence to explain the cash deposits, the Tribunal allowed partial relief by directing a 10% disallowance of the balance amount of the addition. The Tribunal's decision aimed at ensuring fairness and justice, taking into account the circumstances of the case.
Reopening of assessment u/s 147/148 - reasons to believe - The Tribunal upheld the validity of the reopening, considering the reasons recorded by the Assessing Officer as based on tangible material. While the assessee failed to provide satisfactory evidence to explain the cash deposits, the Tribunal allowed partial relief by directing a 10% disallowance of the balance amount of the addition. The Tribunal's decision aimed at ensuring fairness and justice, taking into account the circumstances of the case.
Note: It is a system-generated summary and is for quick reference only.