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 failed to file income tax returns and produce books of accounts. The Commissioner of Income Tax (Appeals) passed a detailed order computing income after obtaining inputs from the assessee, cross-verifying with suppliers, and verifying findings by the Assessing Officer. Although based on assumptions and estimates due to the assessee's lack of transparency, the computation cannot be faulted as the assessee conceded it before the CIT(Appeals). The Income Tax Appellate Tribunal held that the assessee cannot argue against the computation after conceding it, and decided against the assessee regarding the unexplained deposit u/s 69A. Regarding the estimation of net profit on cash deposits, the Tribunal dismissed the Revenue's appeal, upholding the CIT(Appeals)'s correct estimation of taxable net profit instead of considering the entire cash deposit as income.
The assessee failed to file income tax returns and produce books of accounts. The Commissioner of Income Tax (Appeals) passed a detailed order computing income after obtaining inputs from the assessee, cross-verifying with suppliers, and verifying findings by the Assessing Officer. Although based on assumptions and estimates due to the assessee's lack of transparency, the computation cannot be faulted as the assessee conceded it before the CIT(Appeals). The Income Tax Appellate Tribunal held that the assessee cannot argue against the computation after conceding it, and decided against the assessee regarding the unexplained deposit u/s 69A. Regarding the estimation of net profit on cash deposits, the Tribunal dismissed the Revenue's appeal, upholding the CIT(Appeals)'s correct estimation of taxable net profit instead of considering the entire cash deposit as income.
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