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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The Appellate Tribunal addressed the validity of reopening assessment under section 147 and addition under section 69A. The Tribunal held that the AO had sufficient information from DDIT indicating unexplained bank deposits, justifying the belief of income escapement. The assessee's claim of lack of AO's consideration was unsubstantiated and rejected. The Tribunal also dismissed the limitation argument due to the extension granted by TOLA. Regarding the addition under section 69A for cash deposits, the Tribunal found the assessee's explanations and submitted documents credible, highlighting that the books were audited and no discrepancies were reported. As the revenue failed to challenge the evidence, the Tribunal ruled in favor of the assessee, deeming the addition by the AO as unsustainable.
The Appellate Tribunal addressed the validity of reopening assessment under section 147 and addition under section 69A. The Tribunal held that the AO had sufficient information from DDIT indicating unexplained bank deposits, justifying the belief of income escapement. The assessee's claim of lack of AO's consideration was unsubstantiated and rejected. The Tribunal also dismissed the limitation argument due to the extension granted by TOLA. Regarding the addition under section 69A for cash deposits, the Tribunal found the assessee's explanations and submitted documents credible, highlighting that the books were audited and no discrepancies were reported. As the revenue failed to challenge the evidence, the Tribunal ruled in favor of the assessee, deeming the addition by the AO as unsustainable.
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