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 case concerns the reopening of assessment u/s 147 based on information from the Non-filers Monitoring System (NMS) about cash deposits in the assessee's bank account. The Assessing Officer made an addition of unexplained money u/s 69A, partially accepting the assessee's explanation for the cash deposits but rejecting others due to lack of documentary evidence. The Tribunal found that the assessee was deprived of a fair chance to present their case due to procedural deficiencies and reliance on email communication inaccessible to the assessee. The order of the Additional Commissioner of Income Tax (Appeals) was set aside, and the matter was remanded back for fresh adjudication after providing adequate opportunity to the assessee to present their case, in accordance with the principles of natural justice.
The case concerns the reopening of assessment u/s 147 based on information from the Non-filers Monitoring System (NMS) about cash deposits in the assessee's bank account. The Assessing Officer made an addition of unexplained money u/s 69A, partially accepting the assessee's explanation for the cash deposits but rejecting others due to lack of documentary evidence. The Tribunal found that the assessee was deprived of a fair chance to present their case due to procedural deficiencies and reliance on email communication inaccessible to the assessee. The order of the Additional Commissioner of Income Tax (Appeals) was set aside, and the matter was remanded back for fresh adjudication after providing adequate opportunity to the assessee to present their case, in accordance with the principles of natural justice.
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