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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The ITAT upheld the CIT(A)'s deletion of additions made by the Assessing Officer. Regarding the addition of gross profit (GP) shown by increasing the GP rate, the ITAT found the CIT(A)'s findings logical and justified, as the GP rate was lower than the previous year's rate. On the addition u/s 69A for cash deposited in the bank account, the ITAT accepted the CIT(A)'s reliance on non-jurisdictional High Court decisions in the absence of a jurisdictional High Court order. The ITAT agreed with the CIT(A) that without evidence of bogus sales, sales from accepted purchases and stock cannot be rejected. The ITAT dismissed the Revenue's appeal on both grounds.
The ITAT upheld the CIT(A)'s deletion of additions made by the Assessing Officer. Regarding the addition of gross profit (GP) shown by increasing the GP rate, the ITAT found the CIT(A)'s findings logical and justified, as the GP rate was lower than the previous year's rate. On the addition u/s 69A for cash deposited in the bank account, the ITAT accepted the CIT(A)'s reliance on non-jurisdictional High Court decisions in the absence of a jurisdictional High Court order. The ITAT agreed with the CIT(A) that without evidence of bogus sales, sales from accepted purchases and stock cannot be rejected. The ITAT dismissed the Revenue's appeal on both grounds.
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