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 reversed addition made u/s 69A regarding cash deposits during demonetization period. Assessee's regular books of accounts showed recorded sales proceeds, validated by VAT assessment authorities. Sufficient stock inventory supported legitimate sales transactions during the period. No evidence of fictitious purchases or sales to justify cash deposits was established by AO. CIT(A)'s confirmation of addition deemed legally unsustainable. Consequently, application of higher tax rate u/s 115BBE rejected. The tribunal found no basis for treating bank deposits as unexplained money u/s 69A, given proper documentation and business authenticity. Addition deleted in favor of assessee.
ITAT reversed addition made u/s 69A regarding cash deposits during demonetization period. Assessee's regular books of accounts showed recorded sales proceeds, validated by VAT assessment authorities. Sufficient stock inventory supported legitimate sales transactions during the period. No evidence of fictitious purchases or sales to justify cash deposits was established by AO. CIT(A)'s confirmation of addition deemed legally unsustainable. Consequently, application of higher tax rate u/s 115BBE rejected. The tribunal found no basis for treating bank deposits as unexplained money u/s 69A, given proper documentation and business authenticity. Addition deleted in favor of assessee.
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