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 Commissioner of Income Tax (Appeals) confirmed additions from unsecured loans and capital introduced by the assessee during demonetization. The Assessing Officer failed to make inquiries regarding the same, rendering the addition unsustainable. The assessee claimed consideration from jewelry sales, declared as taxable capital gains, and past savings for capital introduced in the proprietary concern. The creditworthiness was proved, and cash deposits from business receipts cannot be concluded as loans. The Commissioner of Income Tax (Appeals) deleted an amount regarding a cheque transaction after examining purchase bills, confirmations, and Income Tax Returns. The assessee provided cash books, sales and purchase books, expense ledgers, loan confirmations, and stock registers. The Income Tax Appellate Tribunal allowed the assessee's appeal and dismissed the revenue's appeal.
The Commissioner of Income Tax (Appeals) confirmed additions from unsecured loans and capital introduced by the assessee during demonetization. The Assessing Officer failed to make inquiries regarding the same, rendering the addition unsustainable. The assessee claimed consideration from jewelry sales, declared as taxable capital gains, and past savings for capital introduced in the proprietary concern. The creditworthiness was proved, and cash deposits from business receipts cannot be concluded as loans. The Commissioner of Income Tax (Appeals) deleted an amount regarding a cheque transaction after examining purchase bills, confirmations, and Income Tax Returns. The assessee provided cash books, sales and purchase books, expense ledgers, loan confirmations, and stock registers. The Income Tax Appellate Tribunal allowed the assessee's appeal and dismissed the revenue's appeal.
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