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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Onus on assessee to explain exorbitant increase in transport expenses and support with proper bills/vouchers, which assessee failed. Sample bills/vouchers not for transport expense, lacking lorry details, origin and destination. Bills for purchase of materials like sand, mentioning 'transportation' but not actual transport expenses. Evidence not explaining abnormal increase in transport expense despite substantial increase in petrol expense. Cogent explanation and complete bills/vouchers lacking, hence addition confirmed by CIT(A) upheld by ITAT. Decided against assessee.
Onus on assessee to explain exorbitant increase in transport expenses and support with proper bills/vouchers, which assessee failed. Sample bills/vouchers not for transport expense, lacking lorry details, origin and destination. Bills for purchase of materials like sand, mentioning 'transportation' but not actual transport expenses. Evidence not explaining abnormal increase in transport expense despite substantial increase in petrol expense. Cogent explanation and complete bills/vouchers lacking, hence addition confirmed by CIT(A) upheld by ITAT. Decided against assessee.
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