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 dismissed the Revenue's appeal and upheld the CIT(A)'s order deleting the addition of Rs. 4 crores u/s 69C. The assessee's books reflected outstanding trade payables to Shri Paranthaman concerns. The seized material and the director's statement were rebutted by the evidence. The ITAT found contradictions and logical flaws in the director's statement relied upon by the AO. The loose sheets did not contain the complete creditors' list and were for reconciliation purposes during account finalization. The assessee established the outstanding trade creditors were allowable and not outside the books.
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s order deleting the addition of Rs. 4 crores u/s 69C. The assessee's books reflected outstanding trade payables to Shri Paranthaman concerns. The seized material and the director's statement were rebutted by the evidence. The ITAT found contradictions and logical flaws in the director's statement relied upon by the AO. The loose sheets did not contain the complete creditors' list and were for reconciliation purposes during account finalization. The assessee established the outstanding trade creditors were allowable and not outside the books.
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