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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Assessee declared cash deposit of Rs. 42 lacs during demonetization period as income. AO made another addition u/s 69A for same amount, treating it as unexplained money and levied tax u/s 115BBE, resulting in double taxation of same income. ITAT held that AO's action of making addition over and above income declared by assessee is wrong and against provisions of Act. Since assessee had already offered cash deposit as income, no separate addition could be made. Appeal allowed.
Assessee declared cash deposit of Rs. 42 lacs during demonetization period as income. AO made another addition u/s 69A for same amount, treating it as unexplained money and levied tax u/s 115BBE, resulting in double taxation of same income. ITAT held that AO's action of making addition over and above income declared by assessee is wrong and against provisions of Act. Since assessee had already offered cash deposit as income, no separate addition could be made. Appeal allowed.
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