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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Disallowance of losses suffered by the appellant on genuine share trading and direct expenses incurred. The key points are: The reasoning given by the Assessing Officer (AO) in the Assessment Order is based on doubts and suspicion rather than facts. A bona fide business arrangement between sister concerns with a signed agreement, not treated as bogus by authorities, cannot be considered a bogus transaction. Losses incurred have been assessed, but the part recovered from the assessee has been added, despite transactions being recorded in audited books. This view of AO/CIT(A) is unsound and additions are deleted. Disallowance of various expenses is rejected as the share trading business was wrongly held bogus. Addition on account of income from house property is upheld as per Section 23, since the property was held for sale and not occupied for residence. No interference with CIT(A)'s order on this issue.
Disallowance of losses suffered by the appellant on genuine share trading and direct expenses incurred. The key points are: The reasoning given by the Assessing Officer (AO) in the Assessment Order is based on doubts and suspicion rather than facts. A bona fide business arrangement between sister concerns with a signed agreement, not treated as bogus by authorities, cannot be considered a bogus transaction. Losses incurred have been assessed, but the part recovered from the assessee has been added, despite transactions being recorded in audited books. This view of AO/CIT(A) is unsound and additions are deleted. Disallowance of various expenses is rejected as the share trading business was wrongly held bogus. Addition on account of income from house property is upheld as per Section 23, since the property was held for sale and not occupied for residence. No interference with CIT(A)'s order on this issue.
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