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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Assessment u/s 153A lacked incriminating material - additions arbitrary. Fictitious commodity losses disallowed due to absence of tangible evidence of undisclosed income or unaccounted assets. Reassessment requires incriminating material as per Saumya Construction case. Unexplained credits u/s 68 deleted as AO failed to verify "source of source" despite assessee providing information. Disallowance u/s 14A r.w.r.8D deleted for unabated years lacking incriminating material, following Saumya Construction and Kabul Chawla cases. Assessee being share dealer doesn't exempt from Section 14A. Revenue's grounds dismissed, assessee's allowed.
Assessment u/s 153A lacked incriminating material - additions arbitrary. Fictitious commodity losses disallowed due to absence of tangible evidence of undisclosed income or unaccounted assets. Reassessment requires incriminating material as per Saumya Construction case. Unexplained credits u/s 68 deleted as AO failed to verify "source of source" despite assessee providing information. Disallowance u/s 14A r.w.r.8D deleted for unabated years lacking incriminating material, following Saumya Construction and Kabul Chawla cases. Assessee being share dealer doesn't exempt from Section 14A. Revenue's grounds dismissed, assessee's allowed.
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