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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Addition u/s 68 - unexplained cash credit received - onus to prove - share capital/premium received by the appellant - The Tribunal (ITAT) found that the assessee failed to prove the creditworthiness of the investor and the genuineness of the transaction. The application for the admission of additional evidence was also rejected, as the assessee had ample opportunities to present this information during the earlier stages of the proceedings.
Addition u/s 68 - unexplained cash credit received - onus to prove - share capital/premium received by the appellant - The Tribunal (ITAT) found that the assessee failed to prove the creditworthiness of the investor and the genuineness of the transaction. The application for the admission of additional evidence was also rejected, as the assessee had ample opportunities to present this information during the earlier stages of the proceedings.
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