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 quantum appeal. It upheld the CIT(A)'s finding that the unexplained cash found during search was part of the income surrendered by the assessee u/s 132(4), based on the statement recorded. Regarding the penalty u/s 271AAB(1)(a), the ITAT deleted it on technical grounds, as the penalty notice did not specify clear charges against the assessee for not fulfilling the conditions and not divulging the source of income, violating natural justice principles.
The ITAT dismissed the Revenue's quantum appeal. It upheld the CIT(A)'s finding that the unexplained cash found during search was part of the income surrendered by the assessee u/s 132(4), based on the statement recorded. Regarding the penalty u/s 271AAB(1)(a), the ITAT deleted it on technical grounds, as the penalty notice did not specify clear charges against the assessee for not fulfilling the conditions and not divulging the source of income, violating natural justice principles.
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