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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CIT(A) deleted addition on unaccounted business income, accepting assessee's retraction of statement recorded u/s 132(4). CIT(A) agreed cash payment of 60 crores by assessee and group entities, over banking channel payment of 50 crores, was from surplus cash, not suppressed sales. CIT(A) observed no legal requirement to produce evidence only during seizure, relying on judicial precedents. CIT(A) elaborated on transactions, noting taxing impugned amount as unaccounted income would lead to double taxation. CIT(A) reconciled cash found during search with completed books, supported by GST returns and bills/vouchers. CIT(A) analyzed sales data from GST returns and books, finding no abnormality. CIT(A) accepted retraction by key person, backed by audited books and reasons. AO's conclusions were incomprehensible, brushing aside substantial evidence without cogent reasons. Statement alone cannot constitute incriminating material u/s 153A. CIT(A)'s decision was justified.
CIT(A) deleted addition on unaccounted business income, accepting assessee's retraction of statement recorded u/s 132(4). CIT(A) agreed cash payment of 60 crores by assessee and group entities, over banking channel payment of 50 crores, was from surplus cash, not suppressed sales. CIT(A) observed no legal requirement to produce evidence only during seizure, relying on judicial precedents. CIT(A) elaborated on transactions, noting taxing impugned amount as unaccounted income would lead to double taxation. CIT(A) reconciled cash found during search with completed books, supported by GST returns and bills/vouchers. CIT(A) analyzed sales data from GST returns and books, finding no abnormality. CIT(A) accepted retraction by key person, backed by audited books and reasons. AO's conclusions were incomprehensible, brushing aside substantial evidence without cogent reasons. Statement alone cannot constitute incriminating material u/s 153A. CIT(A)'s decision was justified.
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