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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U/s 68, the assessee provided relevant details to explain the nature and source of unsecured loans, as well as the interest paid thereon, discharging the primary onus. Once the assessee fulfills this onus, the Assessing Officer (AO) must conduct necessary inquiries and record satisfaction before making any addition. The AO should have exercised powers u/s 133(6) or contacted the concerned AOs of the alleged parties, as their PAN and addresses were available. Following the Supreme Court's decision in Orissa Corpn. and the Tribunal's own decision, the assessee successfully explained the loans' nature, source, and creditors' identity and creditworthiness, proving the transactions' genuineness. Therefore, the CIT(A)'s deletion of the addition u/s 68 and interest disallowance was upheld, dismissing the Revenue's appeal.
U/s 68, the assessee provided relevant details to explain the nature and source of unsecured loans, as well as the interest paid thereon, discharging the primary onus. Once the assessee fulfills this onus, the Assessing Officer (AO) must conduct necessary inquiries and record satisfaction before making any addition. The AO should have exercised powers u/s 133(6) or contacted the concerned AOs of the alleged parties, as their PAN and addresses were available. Following the Supreme Court's decision in Orissa Corpn. and the Tribunal's own decision, the assessee successfully explained the loans' nature, source, and creditors' identity and creditworthiness, proving the transactions' genuineness. Therefore, the CIT(A)'s deletion of the addition u/s 68 and interest disallowance was upheld, dismissing the Revenue's appeal.
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