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 High Court considered an appeal regarding unexplained cash credit u/s 68 of the Income Tax Act. The issue was whether the unsecured loan to the assessee should be treated as income. The court noted that the loan was repaid by the assessee within the financial year. Referring to precedents, the court emphasized that section 68 allows for charging unexplained cash credit as income only if there is no satisfactory explanation. The court clarified that the use of "may" in the provision means that unsatisfactory explanation does not automatically deem the credited amount as income. Consequently, the revenue appeal was found without merit and dismissed.
The High Court considered an appeal regarding unexplained cash credit u/s 68 of the Income Tax Act. The issue was whether the unsecured loan to the assessee should be treated as income. The court noted that the loan was repaid by the assessee within the financial year. Referring to precedents, the court emphasized that section 68 allows for charging unexplained cash credit as income only if there is no satisfactory explanation. The court clarified that the use of "may" in the provision means that unsatisfactory explanation does not automatically deem the credited amount as income. Consequently, the revenue appeal was found without merit and dismissed.
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