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 ITAT held that merely huge profits from share transactions do not make the scrips penny stocks. Despite the financials being incommensurate with purchase/sale prices and characteristics of penny stocks existing, the Revenue failed to link the assessee to dubious transactions, price rigging or establish involvement as entry/exit provider. Absent any material against the assessee's role beyond being an investor for quick profits, the ITAT decided in the assessee's favor, overturning the AO's addition treating share gains as bogus u/s 68, which was based on presumptions and human probabilities without substantiation.
The ITAT held that merely huge profits from share transactions do not make the scrips penny stocks. Despite the financials being incommensurate with purchase/sale prices and characteristics of penny stocks existing, the Revenue failed to link the assessee to dubious transactions, price rigging or establish involvement as entry/exit provider. Absent any material against the assessee's role beyond being an investor for quick profits, the ITAT decided in the assessee's favor, overturning the AO's addition treating share gains as bogus u/s 68, which was based on presumptions and human probabilities without substantiation.
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