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 case involved an appeal regarding assessment under sections 153A or 153C of the Act, focusing on additions under section 69A related to credits in saving accounts and undisclosed profit calculated at 8% on gross receipts in the CC Account. The ITAT decision referenced a previous case where it was held that using a statement from a search of a third party for making additions in the assessee's case was not valid under Section 153C. The ITAT found that the assessment should have been initiated under Section 153C, not 153A, as the mandatory procedure was not followed and the assessee had no opportunity to cross-examine the witness. Consequently, the assessment order under Section 153A was deemed without jurisdiction and quashed, with the appeal by the assessee allowed.
The case involved an appeal regarding assessment under sections 153A or 153C of the Act, focusing on additions under section 69A related to credits in saving accounts and undisclosed profit calculated at 8% on gross receipts in the CC Account. The ITAT decision referenced a previous case where it was held that using a statement from a search of a third party for making additions in the assessee's case was not valid under Section 153C. The ITAT found that the assessment should have been initiated under Section 153C, not 153A, as the mandatory procedure was not followed and the assessee had no opportunity to cross-examine the witness. Consequently, the assessment order under Section 153A was deemed without jurisdiction and quashed, with the appeal by the assessee allowed.
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