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 considered an addition made u/s 68 for the sale of shares as an 'unexplained source of investment'. The assessee, a foreign company tax resident of Mauritius, had held the shares for almost 10 years before selling them. The tribunal found the price increase over the years reasonable, unlike typical penny stock cases. The financials of the company whose shares were sold were substantiated, showing it was not a bogus entity. The AO's concerns about debt levels not correlating with sales were dismissed. The assessee, a SEBI registered FPI, had legitimate income from investments. The tribunal noted a High Court ruling that supported long-term share retention as genuine investment. The ITAT allowed the assessee's appeal, concluding the share transaction was genuine, directing deletion of the addition u/s 68.
The ITAT considered an addition made u/s 68 for the sale of shares as an 'unexplained source of investment'. The assessee, a foreign company tax resident of Mauritius, had held the shares for almost 10 years before selling them. The tribunal found the price increase over the years reasonable, unlike typical penny stock cases. The financials of the company whose shares were sold were substantiated, showing it was not a bogus entity. The AO's concerns about debt levels not correlating with sales were dismissed. The assessee, a SEBI registered FPI, had legitimate income from investments. The tribunal noted a High Court ruling that supported long-term share retention as genuine investment. The ITAT allowed the assessee's appeal, concluding the share transaction was genuine, directing deletion of the addition u/s 68.
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