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...
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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 found AO's calculation of undisclosed income from alleged bogus share purchases to be incorrect. While the broker's contract note was suspended by NSE, no allegations were made against sale transactions or declared profits. The CIT(A)'s deletion of excess addition was upheld. Following precedent from jurisdictional HC in similar cases where 12.5% of bogus purchases was deemed reasonable, ITAT determined the addition confirmed by CIT(A) was unwarranted. The assessee's appeal was allowed, resulting in complete deletion of the disputed addition. The tribunal emphasized that when sales and profits are accepted, merely questioning purchase transactions without substantial evidence is insufficient for sustaining additions.
ITAT found AO's calculation of undisclosed income from alleged bogus share purchases to be incorrect. While the broker's contract note was suspended by NSE, no allegations were made against sale transactions or declared profits. The CIT(A)'s deletion of excess addition was upheld. Following precedent from jurisdictional HC in similar cases where 12.5% of bogus purchases was deemed reasonable, ITAT determined the addition confirmed by CIT(A) was unwarranted. The assessee's appeal was allowed, resulting in complete deletion of the disputed addition. The tribunal emphasized that when sales and profits are accepted, merely questioning purchase transactions without substantial evidence is insufficient for sustaining additions.
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