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 69B r.w.s.115BBE - during the course of survey action discrepancies were found on account of physical verification of stock vis-a-vis regular books of account - The AO and CIT(A) classified this as unexplained investment, leading to a higher tax rate. However, the Tribunal, after considering the facts and various precedents, concluded that the excess stock was indeed related to the regular business operations and not an unexplained investment. Therefore, it directed the AO to assess the surrendered income as business income and apply the normal tax rate, ultimately allowing the assessee's appeal.
Addition u/s 69B r.w.s.115BBE - during the course of survey action discrepancies were found on account of physical verification of stock vis-a-vis regular books of account - The AO and CIT(A) classified this as unexplained investment, leading to a higher tax rate. However, the Tribunal, after considering the facts and various precedents, concluded that the excess stock was indeed related to the regular business operations and not an unexplained investment. Therefore, it directed the AO to assess the surrendered income as business income and apply the normal tax rate, ultimately allowing the assessee's appeal.
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