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...
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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 dismissed Revenue's appeal against CIT(A)'s order deleting additions under s.68 for alleged bogus share capital and unsecured loans. The assessee successfully demonstrated identity, creditworthiness, and transaction genuineness by providing shareholder confirmations, bank statements, and ITRs. AO's additions were rejected as based merely on doubt without contradictory evidence. CIT(A)'s partial allowance of s.14A disallowance was upheld, limiting it to investments yielding exempt income. ITAT affirmed CIT(A)'s authority to admit additional evidence without mandatory AO remand under s.250(4) and Rule 46A(4). The related interest expenses on unsecured loans were consequently allowed, and corresponding adjustments to WIP were permitted.
ITAT dismissed Revenue's appeal against CIT(A)'s order deleting additions under s.68 for alleged bogus share capital and unsecured loans. The assessee successfully demonstrated identity, creditworthiness, and transaction genuineness by providing shareholder confirmations, bank statements, and ITRs. AO's additions were rejected as based merely on doubt without contradictory evidence. CIT(A)'s partial allowance of s.14A disallowance was upheld, limiting it to investments yielding exempt income. ITAT affirmed CIT(A)'s authority to admit additional evidence without mandatory AO remand under s.250(4) and Rule 46A(4). The related interest expenses on unsecured loans were consequently allowed, and corresponding adjustments to WIP were permitted.
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