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 partially allowed the appeal concerning disputed agricultural income and cash deposits during demonetization. The addition of differential agricultural income was deleted as the original return was processed under s.143(1) and not scrutinized. Regarding unexplained cash credits under s.68, ITAT upheld the addition based on lack of evidence for agricultural activity but acknowledged legitimate business transactions from retail trading. The Tribunal rejected retrospective application of enhanced tax rates under s.115BBE, directing taxation at normal rates with applicable surcharges. The assessee's retail business "Shreeji Paints & Ply" provided partial justification for cash deposits, resulting in partial relief against the additions made by the AO.
ITAT partially allowed the appeal concerning disputed agricultural income and cash deposits during demonetization. The addition of differential agricultural income was deleted as the original return was processed under s.143(1) and not scrutinized. Regarding unexplained cash credits under s.68, ITAT upheld the addition based on lack of evidence for agricultural activity but acknowledged legitimate business transactions from retail trading. The Tribunal rejected retrospective application of enhanced tax rates under s.115BBE, directing taxation at normal rates with applicable surcharges. The assessee's retail business "Shreeji Paints & Ply" provided partial justification for cash deposits, resulting in partial relief against the additions made by the AO.
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