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 assessee's contentions were upheld by the Tribunal regarding various additions made by the Assessing Officer. The Tribunal ruled that the RTGS transfer from the assessee's bank account cannot be treated as unexplained cash deposit, and directed the Assessing Officer to delete the addition. The Tribunal also accepted the assessee's explanation regarding the bank statements and held that no addition can be made solely based on AIR information without corroborative evidence. The addition on account of time deposits/fixed deposits was deleted, as the assessee had shown sufficient operating receipts, and the renewal of fixed deposits cannot be questioned unless the original source is doubted. The Tribunal found that the investments in land property were duly reflected in the bank statements, and the delay in cheque clearance cannot lead to an adverse inference. The addition u/s 68 was also deleted, as the assessee established the identity, creditworthiness, and genuineness.
The assessee's contentions were upheld by the Tribunal regarding various additions made by the Assessing Officer. The Tribunal ruled that the RTGS transfer from the assessee's bank account cannot be treated as unexplained cash deposit, and directed the Assessing Officer to delete the addition. The Tribunal also accepted the assessee's explanation regarding the bank statements and held that no addition can be made solely based on AIR information without corroborative evidence. The addition on account of time deposits/fixed deposits was deleted, as the assessee had shown sufficient operating receipts, and the renewal of fixed deposits cannot be questioned unless the original source is doubted. The Tribunal found that the investments in land property were duly reflected in the bank statements, and the delay in cheque clearance cannot lead to an adverse inference. The addition u/s 68 was also deleted, as the assessee established the identity, creditworthiness, and genuineness.
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