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 once the AO found the issue of cash deposit into the assessee's bank account, for which reassessment proceedings were initiated u/s 147, was satisfactorily explained, he lost jurisdiction to make any other additions or disallowances. As the reason for reopening the assessment did not subsist, the AO was required to pass a nil order and any further additions made were illegal. Consequently, the other disallowances u/ss 56 and 80P were held unlawful, and the assessee's appeal was allowed.
The ITAT held that once the AO found the issue of cash deposit into the assessee's bank account, for which reassessment proceedings were initiated u/s 147, was satisfactorily explained, he lost jurisdiction to make any other additions or disallowances. As the reason for reopening the assessment did not subsist, the AO was required to pass a nil order and any further additions made were illegal. Consequently, the other disallowances u/ss 56 and 80P were held unlawful, and the assessee's appeal was allowed.
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