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 made cash deposits during the demonetization period which were treated as unexplained u/s 69A. However, the Tribunal held that the cash deposits were within the normal trends and practices of the business, with cash sales ranging from 87% to 92% of total sales in previous years. The cash deposited during the financial year 2016-17 was lower at 87.92% compared to earlier years, indicating no variance from the established pattern. As the assessee had sufficient cash balance per the accepted books of accounts, the cash deposits could not be treated as undisclosed income. The Tribunal decided in favor of the assessee.
The assessee made cash deposits during the demonetization period which were treated as unexplained u/s 69A. However, the Tribunal held that the cash deposits were within the normal trends and practices of the business, with cash sales ranging from 87% to 92% of total sales in previous years. The cash deposited during the financial year 2016-17 was lower at 87.92% compared to earlier years, indicating no variance from the established pattern. As the assessee had sufficient cash balance per the accepted books of accounts, the cash deposits could not be treated as undisclosed income. The Tribunal decided in favor of the assessee.
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