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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Digital images and Excel files found on partner's phone cannot be relied upon for making additions u/s 69C for unexplained expenditure. Loose papers and documents not corroborated by other evidence are considered dumb documents inadmissible as evidence. Mere entries in seized documents without proof of actual transactions cannot justify additions. Presumptions of imports based solely on electronic files without supporting materials are invalid. Additions made by the Assessing Officer solely relying on such uncorroborated electronic data were rightly deleted by the Tribunal following judicial precedents.
Digital images and Excel files found on partner's phone cannot be relied upon for making additions u/s 69C for unexplained expenditure. Loose papers and documents not corroborated by other evidence are considered dumb documents inadmissible as evidence. Mere entries in seized documents without proof of actual transactions cannot justify additions. Presumptions of imports based solely on electronic files without supporting materials are invalid. Additions made by the Assessing Officer solely relying on such uncorroborated electronic data were rightly deleted by the Tribunal following judicial precedents.
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