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 made u/s. 69A - unexplained cash deposits - The Tribunal found merit in the assessee's argument that the cash on hand at the beginning of the financial year could reasonably explain the subsequent deposits during demonetization. - The Tribunal highlighted that previous judicial decisions have supported the notion that mere time gaps between cash withdrawals and deposits are not sufficient grounds for additions under Sec. 69A if the assessee provides a coherent trail of the cash flow.
Addition made u/s. 69A - unexplained cash deposits - The Tribunal found merit in the assessee's argument that the cash on hand at the beginning of the financial year could reasonably explain the subsequent deposits during demonetization. - The Tribunal highlighted that previous judicial decisions have supported the notion that mere time gaps between cash withdrawals and deposits are not sufficient grounds for additions under Sec. 69A if the assessee provides a coherent trail of the cash flow.
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