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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT upheld the CIT(A)'s rejection of the assessee's books of account u/s 145(3) as inaccurate, unreliable, and incapable of reflecting true financial affairs. It concurred with CIT(A)'s estimation of profit based on average net profit earned on regular receipts, deeming the methodology logical. Separate additions u/ss 37(1) and 40A(3) were rightly deleted once books were rejected and income estimated on gross receipts, relying on Madras HC's decision in CIT v. Amman Steel. For AY 2021-22, granting telescoping benefit against cash seized was justified as the assessee offered substantial additional income for prior years exceeding seized cash.
The ITAT upheld the CIT(A)'s rejection of the assessee's books of account u/s 145(3) as inaccurate, unreliable, and incapable of reflecting true financial affairs. It concurred with CIT(A)'s estimation of profit based on average net profit earned on regular receipts, deeming the methodology logical. Separate additions u/ss 37(1) and 40A(3) were rightly deleted once books were rejected and income estimated on gross receipts, relying on Madras HC's decision in CIT v. Amman Steel. For AY 2021-22, granting telescoping benefit against cash seized was justified as the assessee offered substantial additional income for prior years exceeding seized cash.
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