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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Cash deposits in bank accounts were challenged by AO under section 69A as unexplained. Assessee demonstrated deposits originated from legitimate cash sales recorded in books of account, with complete documentation of purchases, sales, and inventory details. ITAT held that since individual cash transactions were below Rs. 2 lakh threshold, no customer PAN details were required. The tribunal accepted assessee's explanation that deposits during April-May 2019 were from regular business operations. CIT(A)/NFAC's reasoning was upheld, concluding section 69A provisions were inapplicable given proper documentation of source. Revenue's appeal dismissed as assessee successfully established nature and source of deposits through verifiable business records.
Cash deposits in bank accounts were challenged by AO under section 69A as unexplained. Assessee demonstrated deposits originated from legitimate cash sales recorded in books of account, with complete documentation of purchases, sales, and inventory details. ITAT held that since individual cash transactions were below Rs. 2 lakh threshold, no customer PAN details were required. The tribunal accepted assessee's explanation that deposits during April-May 2019 were from regular business operations. CIT(A)/NFAC's reasoning was upheld, concluding section 69A provisions were inapplicable given proper documentation of source. Revenue's appeal dismissed as assessee successfully established nature and source of deposits through verifiable business records.
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