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 two key issues. Firstly, regarding the addition u/s 68, it was found that the investors' transactions were genuine, evidenced by banking records and supporting documents. The burden of proof shifted to the AO, who failed to provide evidence of wrongdoing. Some investors responded to notices, further validating the transactions. The AO's claim of cash deposits was disproven, leading to deletion of the addition. Secondly, the notional interest added lacked legal basis as the loans were interest-free and no deduction was claimed. The absence of a business connection with the borrower precluded the addition. Citing precedent, the Tribunal upheld the deletion of the notional interest addition. Ultimately, the appeal by the assessee was allowed.
The Appellate Tribunal addressed two key issues. Firstly, regarding the addition u/s 68, it was found that the investors' transactions were genuine, evidenced by banking records and supporting documents. The burden of proof shifted to the AO, who failed to provide evidence of wrongdoing. Some investors responded to notices, further validating the transactions. The AO's claim of cash deposits was disproven, leading to deletion of the addition. Secondly, the notional interest added lacked legal basis as the loans were interest-free and no deduction was claimed. The absence of a business connection with the borrower precluded the addition. Citing precedent, the Tribunal upheld the deletion of the notional interest addition. Ultimately, the appeal by the assessee was allowed.
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