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 ruled against addition under s.68 regarding unexplained cash credits from company directors. Directors made payments to 169 individuals for property acquisition on company's behalf, rather than direct loans to company. Documentation included payment confirmations and proper balance sheet entries showing director liabilities. Tribunal held that assessee discharged burden of proof by demonstrating genuine nature of transactions through third-party confirmations and establishing clear money trail for property purchases. The fact that directors obtained unsecured loans to make these payments did not justify addition under s.68 when supported by comprehensive documentation. Addition made by AO and upheld by CIT(A) was deleted.
ITAT ruled against addition under s.68 regarding unexplained cash credits from company directors. Directors made payments to 169 individuals for property acquisition on company's behalf, rather than direct loans to company. Documentation included payment confirmations and proper balance sheet entries showing director liabilities. Tribunal held that assessee discharged burden of proof by demonstrating genuine nature of transactions through third-party confirmations and establishing clear money trail for property purchases. The fact that directors obtained unsecured loans to make these payments did not justify addition under s.68 when supported by comprehensive documentation. Addition made by AO and upheld by CIT(A) was deleted.
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