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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Unexplained Cash Credit u/s 68 - Authenticity of the Will - sale consideration claimed to have been received by the appellant from sale of gold ornament and diamonds, which were given to him by his late grandmother by way of a will - The Tribunal noted the discrepancies in the age of the testator and absence of probate were crucial in questioning the authenticity of the Will. The appellant failed to provide independent evidence to corroborate the existence and possession of the assets at the time the Will was made. The Tribunal found it improbable that a housewife without a visible source of income could possess such high-value assets. Consequently, the appeal of the assessee was dismissed.
Unexplained Cash Credit u/s 68 - Authenticity of the Will - sale consideration claimed to have been received by the appellant from sale of gold ornament and diamonds, which were given to him by his late grandmother by way of a will - The Tribunal noted the discrepancies in the age of the testator and absence of probate were crucial in questioning the authenticity of the Will. The appellant failed to provide independent evidence to corroborate the existence and possession of the assets at the time the Will was made. The Tribunal found it improbable that a housewife without a visible source of income could possess such high-value assets. Consequently, the appeal of the assessee was dismissed.
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