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 r.w.s. 115BBE - assessee deposited cash during demonetization period - The Appellate Tribunal found the appellant's claim backed by sufficient documentary evidence, concluding that no addition could be made solely based on suspicion. As the cash generated from sales was duly reflected in the books of accounts, the provisions of Sec. 69A were not applicable. Ultimately, the Tribunal allowed the appellant's appeal, overturning the additions made by the assessing authority.
Addition u/s 69A r.w.s. 115BBE - assessee deposited cash during demonetization period - The Appellate Tribunal found the appellant's claim backed by sufficient documentary evidence, concluding that no addition could be made solely based on suspicion. As the cash generated from sales was duly reflected in the books of accounts, the provisions of Sec. 69A were not applicable. Ultimately, the Tribunal allowed the appellant's appeal, overturning the additions made by the assessing authority.
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