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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Addition u/s 69A - AIR information revealed cash deposits in assessee's savings bank account - assessee applied Section 44AD of the Act on business income. Held: Assessee was a contractor before appointment, and Revenue did not dispute this. Section 44AD allows computing business profits on presumptive basis for eligible businesses at 8% of turnover. Assessee's business fell under eligible category. AO did not provide evidence that cash deposits were not from business. In absence of contrary evidence, assessee's business was eligible u/s 44AD, and cash deposits were from business. 10% profit offered by assessee u/s 44AD accepted. CIT(A)'s order failed, assessee's grounds allowed.
Addition u/s 69A - AIR information revealed cash deposits in assessee's savings bank account - assessee applied Section 44AD of the Act on business income. Held: Assessee was a contractor before appointment, and Revenue did not dispute this. Section 44AD allows computing business profits on presumptive basis for eligible businesses at 8% of turnover. Assessee's business fell under eligible category. AO did not provide evidence that cash deposits were not from business. In absence of contrary evidence, assessee's business was eligible u/s 44AD, and cash deposits were from business. 10% profit offered by assessee u/s 44AD accepted. CIT(A)'s order failed, assessee's grounds allowed.
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