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 money u/s 69A - deposits in bank account during the demonetization period - joint bank account of husband wife - family settlement - The Appellate Tribunal noted that the appellant's wife had filed a settlement deed and affidavit confirming the source of the cash deposits, which were from her own savings. It observed that the appellant's wife had provided sufficient evidence to support the source of certain cash deposits. - The addition made by the lower authorities was deemed unsustainable, and thus, the same was directed to be deleted.
Unexplained money u/s 69A - deposits in bank account during the demonetization period - joint bank account of husband wife - family settlement - The Appellate Tribunal noted that the appellant's wife had filed a settlement deed and affidavit confirming the source of the cash deposits, which were from her own savings. It observed that the appellant's wife had provided sufficient evidence to support the source of certain cash deposits. - The addition made by the lower authorities was deemed unsustainable, and thus, the same was directed to be deleted.
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