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 ITAT held that the addition u/s 69C r.w.s.115BBE for unexplained import expenditure was justified as the assessee failed to record the expenditure in the books. Lack of proof of past business relation with China-based supplier raised doubts on credit imports. The payment of custom duty was acknowledged, but the explanation provided did not meet the standard of human probabilities. The assessee's failure to prove import agreement conditions led to dismissal of the appeal. The alternative plea for relief on custom duty was rejected as lower authorities had already granted relief and sec.69C proviso barred further addition. Assessee's appeal was dismissed.
The ITAT held that the addition u/s 69C r.w.s.115BBE for unexplained import expenditure was justified as the assessee failed to record the expenditure in the books. Lack of proof of past business relation with China-based supplier raised doubts on credit imports. The payment of custom duty was acknowledged, but the explanation provided did not meet the standard of human probabilities. The assessee's failure to prove import agreement conditions led to dismissal of the appeal. The alternative plea for relief on custom duty was rejected as lower authorities had already granted relief and sec.69C proviso barred further addition. Assessee's appeal was dismissed.
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