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 Assessing Officer (AO) made additions u/ss 69C and 68 for undisclosed credit card expenditures in foreign currencies based on material found during a survey. The assessee possessed various international credit cards belonging to friends and relatives, enabling utilization without their presence. Despite requests, the assessee failed to provide details or explanations. The AO reopened the assessment and issued a notice u/s 143(2) to investigate further. In the absence of any material or evidence from the assessee or card owners, the AO treated the funds as unexplained income u/ss 68 and 69C. The CIT(A) upheld the additions, distinguishing the case from cited decisions. Regarding the protective addition for unexplained money received through Ananda Heritage Hotels P. Ltd., the ITAT observed that the investment was made through Wilton Investment Ltd., and the substantive addition was made in Ananda Heritage Hotels P. Ltd.'s hands. The CIT(A) deleted the protective addition in the assessee's hands, which the ITAT upheld, dismissing the Revenue's appeal.
The Assessing Officer (AO) made additions u/ss 69C and 68 for undisclosed credit card expenditures in foreign currencies based on material found during a survey. The assessee possessed various international credit cards belonging to friends and relatives, enabling utilization without their presence. Despite requests, the assessee failed to provide details or explanations. The AO reopened the assessment and issued a notice u/s 143(2) to investigate further. In the absence of any material or evidence from the assessee or card owners, the AO treated the funds as unexplained income u/ss 68 and 69C. The CIT(A) upheld the additions, distinguishing the case from cited decisions. Regarding the protective addition for unexplained money received through Ananda Heritage Hotels P. Ltd., the ITAT observed that the investment was made through Wilton Investment Ltd., and the substantive addition was made in Ananda Heritage Hotels P. Ltd.'s hands. The CIT(A) deleted the protective addition in the assessee's hands, which the ITAT upheld, dismissing the Revenue's appeal.
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