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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Unexplained investments in the form of Specified Bank Notes (SBNs) deposited during demonetization period were questioned. The assessee claimed the deposits were trade receipts from milk and milk product sales, offering to provide customer details. The CBDT circular mandates analyzing the assessee's business model, books, and sales. No significant change in cash deposits during demonetization indicates the explained source cannot be disregarded solely for accepting demonetized currency. The assessee maintained audited books proving the cash/SBNs were part of the taxed turnover. Making a separate addition would lead to double taxation. Hence, the decision favored the assessee, as the amount deposited was already offered for taxation as part of turnover.
Unexplained investments in the form of Specified Bank Notes (SBNs) deposited during demonetization period were questioned. The assessee claimed the deposits were trade receipts from milk and milk product sales, offering to provide customer details. The CBDT circular mandates analyzing the assessee's business model, books, and sales. No significant change in cash deposits during demonetization indicates the explained source cannot be disregarded solely for accepting demonetized currency. The assessee maintained audited books proving the cash/SBNs were part of the taxed turnover. Making a separate addition would lead to double taxation. Hence, the decision favored the assessee, as the amount deposited was already offered for taxation as part of turnover.
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