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 68 cannot be made solely based on sworn statement recorded u/s 132(4) without corroborative materials. Onus lies on the Department to collect cogent evidence to corroborate notings on loose sheets. Additions cannot be made based on assumptions, suspicions, or irrelevant inadmissible material. Capital gains should be taxed on actual gains, not fictional income. Unless evidence shows more was received than stated, no higher price can be the basis for addition. Issue remitted to Assessing Officer to re-examine if ingredients of section 68 are present based on corroborative seized material, not statements u/s 132(4) or 131. For section 69B and 69C additions in assessment years 2017-18 and 2018-19, additions based on unsubstantiated seized material and statements u/s 132(4) cannot be sustained. Accordingly, additions deleted.
Addition u/s 68 cannot be made solely based on sworn statement recorded u/s 132(4) without corroborative materials. Onus lies on the Department to collect cogent evidence to corroborate notings on loose sheets. Additions cannot be made based on assumptions, suspicions, or irrelevant inadmissible material. Capital gains should be taxed on actual gains, not fictional income. Unless evidence shows more was received than stated, no higher price can be the basis for addition. Issue remitted to Assessing Officer to re-examine if ingredients of section 68 are present based on corroborative seized material, not statements u/s 132(4) or 131. For section 69B and 69C additions in assessment years 2017-18 and 2018-19, additions based on unsubstantiated seized material and statements u/s 132(4) cannot be sustained. Accordingly, additions deleted.
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