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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Ex-parte assessment u/s 144 treated unexplained cash deposits as undisclosed and unexplained income, added to the assessee's total income u/s 68 read with Section 69A. Where sums are credited in the assessee's books, the same may be charged as income if the assessee's explanation is unsatisfactory, creating prima facie evidence against the assessee. The burden is on the assessee to rebut the presumption of income receipt. In this case, despite notices, the assessee did not appear or furnish explanations before the authorities. The belated explanation of amounts collected as a recovery agent was found unreasonable. The AO, CIT(Appeals), NFAC, and ITAT concurrently concluded that the assessee failed to rebut the presumption u/s 68 read with Section 69A. Following the Supreme Court's decision in Vijay Kumar Talwar, the ITAT's finding based on records is correct, and no substantial question of law arises. The appeal is dismissed at the admission stage without notice to the other side.
Ex-parte assessment u/s 144 treated unexplained cash deposits as undisclosed and unexplained income, added to the assessee's total income u/s 68 read with Section 69A. Where sums are credited in the assessee's books, the same may be charged as income if the assessee's explanation is unsatisfactory, creating prima facie evidence against the assessee. The burden is on the assessee to rebut the presumption of income receipt. In this case, despite notices, the assessee did not appear or furnish explanations before the authorities. The belated explanation of amounts collected as a recovery agent was found unreasonable. The AO, CIT(Appeals), NFAC, and ITAT concurrently concluded that the assessee failed to rebut the presumption u/s 68 read with Section 69A. Following the Supreme Court's decision in Vijay Kumar Talwar, the ITAT's finding based on records is correct, and no substantial question of law arises. The appeal is dismissed at the admission stage without notice to the other side.
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