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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ITAT quashed reassessment proceedings regarding alleged undisclosed "on-money" payments to builder for residential property. AO's reliance on pen drive and documents seized during third-party search operation deemed insufficient without corroborative evidence. Assessee consistently denied making cash payments above agreement value. Critical procedural deficiencies noted: seized materials not confronted with assessee, statements under s.131 not shared, and no explicit mention of assessee in seized documents. ITAT emphasized that uncorroborated digital evidence from third-party searches cannot constitute credible basis for reassessment. Violation of natural justice principles where adverse materials not provided to assessee. Addition deleted as AO failed to establish authenticity of digital evidence or verify reliability of pen drive data.
ITAT quashed reassessment proceedings regarding alleged undisclosed "on-money" payments to builder for residential property. AO's reliance on pen drive and documents seized during third-party search operation deemed insufficient without corroborative evidence. Assessee consistently denied making cash payments above agreement value. Critical procedural deficiencies noted: seized materials not confronted with assessee, statements under s.131 not shared, and no explicit mention of assessee in seized documents. ITAT emphasized that uncorroborated digital evidence from third-party searches cannot constitute credible basis for reassessment. Violation of natural justice principles where adverse materials not provided to assessee. Addition deleted as AO failed to establish authenticity of digital evidence or verify reliability of pen drive data.
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