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 case pertains to an unexplained investment u/s 69B, where an addition was made on account of cash payment for the purchase of land. The Assessing Officer relied on a 'satakat' found from the hard disk of an advocate, Turnish Kania, which matched the details of the land purchase by the assessee. The Tribunal observed that the assessee had filed detailed written submissions, contrary to the CIT(A)'s observation. Referring to the case of Kalpesh Mafatlal Patel, where a similar unsigned and undated 'satakat' found from the same advocate was held inadmissible, the Tribunal allowed the assessee's appeal, stating that no addition can be made based on such a document from an unconnected person without specific queries raised. The summary highlights the evidentiary value of the 'satakat' and the principles regarding unexplained investments u/s 69B.
The case pertains to an unexplained investment u/s 69B, where an addition was made on account of cash payment for the purchase of land. The Assessing Officer relied on a 'satakat' found from the hard disk of an advocate, Turnish Kania, which matched the details of the land purchase by the assessee. The Tribunal observed that the assessee had filed detailed written submissions, contrary to the CIT(A)'s observation. Referring to the case of Kalpesh Mafatlal Patel, where a similar unsigned and undated 'satakat' found from the same advocate was held inadmissible, the Tribunal allowed the assessee's appeal, stating that no addition can be made based on such a document from an unconnected person without specific queries raised. The summary highlights the evidentiary value of the 'satakat' and the principles regarding unexplained investments u/s 69B.
Note: It is a system-generated summary and is for quick reference only.