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...
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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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This case pertains to the addition made u/s 69A of the Income Tax Act regarding unexplained cash found during a search operation. The assessee produced a cash book to explain the cash, but the Departmental Representative argued that maintaining a cash book is not mandatory for individuals, and the cash book was an afterthought. The CIT(A) disbelieved the cash book solely on the ground that individuals generally do not maintain cash books, without any substantive basis. The CIT(A) treated the amount as explained on an estimated basis and confirmed the remaining addition. The ITAT held that the CIT(A)'s findings on the cash book were baseless and perverse. Since the assessee produced the cash book and explained the cash found during the search, contending it belonged to family members, and the Panchnama drawn during the search also mentioned the names of the assessee and other family members, the authorities erred in making/sustaining the addition. Consequently, the assessee's appeal was allowed.
This case pertains to the addition made u/s 69A of the Income Tax Act regarding unexplained cash found during a search operation. The assessee produced a cash book to explain the cash, but the Departmental Representative argued that maintaining a cash book is not mandatory for individuals, and the cash book was an afterthought. The CIT(A) disbelieved the cash book solely on the ground that individuals generally do not maintain cash books, without any substantive basis. The CIT(A) treated the amount as explained on an estimated basis and confirmed the remaining addition. The ITAT held that the CIT(A)'s findings on the cash book were baseless and perverse. Since the assessee produced the cash book and explained the cash found during the search, contending it belonged to family members, and the Panchnama drawn during the search also mentioned the names of the assessee and other family members, the authorities erred in making/sustaining the addition. Consequently, the assessee's appeal was allowed.
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