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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Validity of additions made u/s 153A, 69C, 68, and 69A of the Income Tax Act. It discusses the lack of incriminating material or documents found during the search to justify additions based on the Department Valuation Officer's report. The summary cites relevant case laws, including Narula Educational Trust, Abhisar Buildwell P. Ltd., B.G.Shirke Construction Technology Pvt Ltd., and Dialust, to support the arguments. It also addresses the issue of additions made based on the departmental valuation report, highlighting the lack of proper inquiry by the Assessing Officer. Additionally, it covers the addition u/s 68 towards unsecured loans, stating that the addition was unjustified as the assessee proved the genuineness of the transactions. The summary provides a concise overview of the critical legal issues and arguments presented in the case.
Validity of additions made u/s 153A, 69C, 68, and 69A of the Income Tax Act. It discusses the lack of incriminating material or documents found during the search to justify additions based on the Department Valuation Officer's report. The summary cites relevant case laws, including Narula Educational Trust, Abhisar Buildwell P. Ltd., B.G.Shirke Construction Technology Pvt Ltd., and Dialust, to support the arguments. It also addresses the issue of additions made based on the departmental valuation report, highlighting the lack of proper inquiry by the Assessing Officer. Additionally, it covers the addition u/s 68 towards unsecured loans, stating that the addition was unjustified as the assessee proved the genuineness of the transactions. The summary provides a concise overview of the critical legal issues and arguments presented in the case.
Note: It is a system-generated summary and is for quick reference only.
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