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 on the basis of whatsapp messages - The ITAT noted that the mere presence of WhatsApp messages on a mobile phone does not conclusively prove that the transactions mentioned therein were undertaken by the phone's owner. It was emphasized that such messages could be exchanged in various contexts not necessarily related to undisclosed income. - The tribunal agreed with the appellant that there was an erroneous double addition for a single transaction amount calculated in both dollars and rupees, which amounted to a computational error by the AO.
Addition u/s 69A on the basis of whatsapp messages - The ITAT noted that the mere presence of WhatsApp messages on a mobile phone does not conclusively prove that the transactions mentioned therein were undertaken by the phone's owner. It was emphasized that such messages could be exchanged in various contexts not necessarily related to undisclosed income. - The tribunal agreed with the appellant that there was an erroneous double addition for a single transaction amount calculated in both dollars and rupees, which amounted to a computational error by the AO.
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