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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In a case regarding GP estimation, the Assessing Officer (AO) applied an 8% profit rate on the assessee's turnover, which did not match Form 26AS. The CIT(A), considering past orders, estimated 7% profit. However, the Tribunal held that since the assessee had already disclosed 5.99% profit, no further estimation was required. The profit from the disputed Sri Lanka project was part of the total declared profit. Consequently, the assessee's appeal was allowed, and the AO's estimation was rejected by the ITAT (Appellate Tribunal).
In a case regarding GP estimation, the Assessing Officer (AO) applied an 8% profit rate on the assessee's turnover, which did not match Form 26AS. The CIT(A), considering past orders, estimated 7% profit. However, the Tribunal held that since the assessee had already disclosed 5.99% profit, no further estimation was required. The profit from the disputed Sri Lanka project was part of the total declared profit. Consequently, the assessee's appeal was allowed, and the AO's estimation was rejected by the ITAT (Appellate Tribunal).
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