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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Revision u/s 263 - source of cash found in the course of search remains unexplained and additions u/s 69A r.w. Section 115BBE - The Tribunal found merit in the appellant's defense regarding the source of cash found during the search. It noted that the appellant had provided reasonable explanations, including references to previous years' balances, which were accepted by the Assessing Officer (AO). - Regarding the issue of jewellery, the Tribunal highlighted the lack of opportunity provided to the appellant by the Pr.CIT to address this matter. It emphasized that principles of natural justice were breached, as the appellant was not given a chance to defend against the allegations related to jewellery. Ultimately, the Tribunal set aside the revisional order and upheld the appellant's appeals.
Revision u/s 263 - source of cash found in the course of search remains unexplained and additions u/s 69A r.w. Section 115BBE - The Tribunal found merit in the appellant's defense regarding the source of cash found during the search. It noted that the appellant had provided reasonable explanations, including references to previous years' balances, which were accepted by the Assessing Officer (AO). - Regarding the issue of jewellery, the Tribunal highlighted the lack of opportunity provided to the appellant by the Pr.CIT to address this matter. It emphasized that principles of natural justice were breached, as the appellant was not given a chance to defend against the allegations related to jewellery. Ultimately, the Tribunal set aside the revisional order and upheld the appellant's appeals.
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