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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Addition u/s 69A - unexplained income - cash deposits made into bank account during demonetization period - assessee neither furnished stock summary nor bills/vouchers for purchases - cash deposits recorded in books of account, audited, tax audit report furnished - assessee explained cash deposits of Rs. 69.25 lakhs, Rs. 13 lakhs from sales to party, remaining from cash sales during Diwali before demonetization - AO did not reject books of accounts - assessee's contention of receiving Rs. 13.95 lakhs cash from party not disputed - no cash collection by assessee after demonetization - coordinate Bench ruling that when audited books not rejected and sales not disturbed, no addition u/s 68 for cash deposits during demonetization - no addition u/s 69A for cash deposits as unexplained income - CIT(A)'s findings reversed, addition deleted.
Addition u/s 69A - unexplained income - cash deposits made into bank account during demonetization period - assessee neither furnished stock summary nor bills/vouchers for purchases - cash deposits recorded in books of account, audited, tax audit report furnished - assessee explained cash deposits of Rs. 69.25 lakhs, Rs. 13 lakhs from sales to party, remaining from cash sales during Diwali before demonetization - AO did not reject books of accounts - assessee's contention of receiving Rs. 13.95 lakhs cash from party not disputed - no cash collection by assessee after demonetization - coordinate Bench ruling that when audited books not rejected and sales not disturbed, no addition u/s 68 for cash deposits during demonetization - no addition u/s 69A for cash deposits as unexplained income - CIT(A)'s findings reversed, addition deleted.
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