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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Cash withdrawals from ICICI and SBI bank accounts were treated as the source for deposits made during demonetization, as evidence showed the withdrawn funds were not used for other purposes. The burden of disproving availability of withdrawn cash for deposits lies with the Department. However, the claim of deposits originating from USD conversion was rejected due to lack of forex receipts and documentation from authorized money exchangers. As a result, an addition of Rs. 3,70,000/- was sustained u/s 69A for unexplained income. The penalty u/s 271AAC and interest u/ss 234A, 234B, and 234C will be recomputed based on the revised assessed income by the Assessing Officer. The Appellate Tribunal's decision was based on judicial precedents and evidentiary requirements for regulated foreign exchange transactions.
Cash withdrawals from ICICI and SBI bank accounts were treated as the source for deposits made during demonetization, as evidence showed the withdrawn funds were not used for other purposes. The burden of disproving availability of withdrawn cash for deposits lies with the Department. However, the claim of deposits originating from USD conversion was rejected due to lack of forex receipts and documentation from authorized money exchangers. As a result, an addition of Rs. 3,70,000/- was sustained u/s 69A for unexplained income. The penalty u/s 271AAC and interest u/ss 234A, 234B, and 234C will be recomputed based on the revised assessed income by the Assessing Officer. The Appellate Tribunal's decision was based on judicial precedents and evidentiary requirements for regulated foreign exchange transactions.
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