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 made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing unique code assigned for operation of foreign bank account - Revenue possessed overwhelming material indicating assessee held foreign bank account which assessee refused to confirm by not providing consent waiver form citing self-incrimination plea rejected as not maintainable - adverse inference drawn from assessee's conduct and undertaking - addition of imputed interest income not sustainable as bank account closed before relevant period. Addition on unexplained investment in jewelry - part addition deleted for jewelry received as wedding gifts with supporting evidence, balance addition confirmed for lack of proper details regarding jewelry claimed as received on children's birthdays.
Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing unique code assigned for operation of foreign bank account - Revenue possessed overwhelming material indicating assessee held foreign bank account which assessee refused to confirm by not providing consent waiver form citing self-incrimination plea rejected as not maintainable - adverse inference drawn from assessee's conduct and undertaking - addition of imputed interest income not sustainable as bank account closed before relevant period. Addition on unexplained investment in jewelry - part addition deleted for jewelry received as wedding gifts with supporting evidence, balance addition confirmed for lack of proper details regarding jewelry claimed as received on children's birthdays.
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