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 in favor of the assessee regarding disputed cash deposits and property investments made through NRE account. The tribunal rejected revenue authorities' contentions about unexplained sources of 50,000 USD cash deposit, finding sufficient documentary evidence proving withdrawal from South African company SPPL where assessee's spouse was director. ITAT dismissed DRP's reasoning that physical transport of dollars was suspicious as irrelevant to transaction legitimacy. Similarly, property investment sourced from foreign entity and registration charges funded by assessee's son through documented transfers were deemed adequately explained. The tribunal emphasized that transactions through NRE account, supported by evidence of foreign source funds from companies where assessee/spouse held positions or family member advances, satisfied burden of proof for transaction genuineness.
ITAT ruled in favor of the assessee regarding disputed cash deposits and property investments made through NRE account. The tribunal rejected revenue authorities' contentions about unexplained sources of 50,000 USD cash deposit, finding sufficient documentary evidence proving withdrawal from South African company SPPL where assessee's spouse was director. ITAT dismissed DRP's reasoning that physical transport of dollars was suspicious as irrelevant to transaction legitimacy. Similarly, property investment sourced from foreign entity and registration charges funded by assessee's son through documented transfers were deemed adequately explained. The tribunal emphasized that transactions through NRE account, supported by evidence of foreign source funds from companies where assessee/spouse held positions or family member advances, satisfied burden of proof for transaction genuineness.
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