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...
The ITAT held that the CIT (A) erred in admitting additional evidence without following Rule 46A. Deletion of additions on forfeited amount and various expenses was justified. The Delhi High Court precedent supported treating forfeited advance as business expenditure. The CIT (A) deleted disallowance of various expenses due to lack of AO's remand report. The ITAT upheld the deletion of disallowance u/s 14A. The case was remanded to CIT (A) for compliance with Rule 46A and fresh decision on specified grounds.
The ITAT held that the CIT (A) erred in admitting additional evidence without following Rule 46A. Deletion of additions on forfeited amount and various expenses was justified. The Delhi High Court precedent supported treating forfeited advance as business expenditure. The CIT (A) deleted disallowance of various expenses due to lack of AO's remand report. The ITAT upheld the deletion of disallowance u/s 14A. The case was remanded to CIT (A) for compliance with Rule 46A and fresh decision on specified grounds.
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