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 upheld partial rejection of books under s.145(3) due to unverifiable self-made cash vouchers, though specific quantification was lacking. Given turnover of Rs.4,00,48,401 showing only 4% variance from previous year, ITAT confirmed addition of Rs.1,00,000 despite assessee's tax audit report and claimed receipted vouchers. On interest income from JSPL reflected under business income, matter remanded to AO for verification whether funds were invested for business expediency rather than mere surplus fund investment to determine appropriate head of income classification between business income versus income from other sources. Addition sustained but limited to Rs.1,00,000 considering overall circumstances and to end protracted litigation.
ITAT upheld partial rejection of books under s.145(3) due to unverifiable self-made cash vouchers, though specific quantification was lacking. Given turnover of Rs.4,00,48,401 showing only 4% variance from previous year, ITAT confirmed addition of Rs.1,00,000 despite assessee's tax audit report and claimed receipted vouchers. On interest income from JSPL reflected under business income, matter remanded to AO for verification whether funds were invested for business expediency rather than mere surplus fund investment to determine appropriate head of income classification between business income versus income from other sources. Addition sustained but limited to Rs.1,00,000 considering overall circumstances and to end protracted litigation.
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