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 Income Tax Appellate Tribunal held that the revised return of income filed by the assessee cannot be treated as invalid by the Assessing Officer (AO). Since the AO issued notice u/s 143(2) based on the revised return and completed the assessment considering the same, the revised return should be deemed valid. Consequently, no addition u/s 68 for the cash difference between the original and revised returns is warranted. Further, the Tribunal observed that the Department did not dispute the turnover admitted in the revised VAT returns, which reflected an increase in sales. The closing stock and cash on hand matched the cash deposits in the bank account. Therefore, the addition confirmed by the CIT(A) was unjustified.
The Income Tax Appellate Tribunal held that the revised return of income filed by the assessee cannot be treated as invalid by the Assessing Officer (AO). Since the AO issued notice u/s 143(2) based on the revised return and completed the assessment considering the same, the revised return should be deemed valid. Consequently, no addition u/s 68 for the cash difference between the original and revised returns is warranted. Further, the Tribunal observed that the Department did not dispute the turnover admitted in the revised VAT returns, which reflected an increase in sales. The closing stock and cash on hand matched the cash deposits in the bank account. Therefore, the addition confirmed by the CIT(A) was unjustified.
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