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 deposit during demonetization period treated as unexplained cash credit. Assessee's claim of introducing cash as capital in proprietary concern not accepted due to lack of evidence regarding availability of substantial cash. AO's view upheld that assessee's cash withdrawals from bank accounts indicate absence of substantial personal cash holdings. Assessee's cash in hand on date of deposit reduced by alleged capital introduction amount. Remaining cash in hand treated as source for deposit, with balance addition treated as unexplained cash credit. Appeal partly allowed.
Cash deposit during demonetization period treated as unexplained cash credit. Assessee's claim of introducing cash as capital in proprietary concern not accepted due to lack of evidence regarding availability of substantial cash. AO's view upheld that assessee's cash withdrawals from bank accounts indicate absence of substantial personal cash holdings. Assessee's cash in hand on date of deposit reduced by alleged capital introduction amount. Remaining cash in hand treated as source for deposit, with balance addition treated as unexplained cash credit. Appeal partly allowed.
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