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 against revenue's extrapolation of alleged on-money receipts from shop sales based on loose papers found during search. The tribunal noted that sales manager A's statement denying receipt of on-money was not properly confronted with discrepancies, and no buyers were examined during search or assessment proceedings. Following precedents from Madras HC and Kerala HC, statements recorded under Section 133A lack evidentiary value. Without corroborating evidence, cash recovery, or buyer verification, the extrapolation for three assessment years was deemed unjustified. The tribunal emphasized that while search evidence can be used per Supreme Court's Pooran Mal ruling, it requires corroboration. Appeal partly allowed for all three years.
ITAT ruled against revenue's extrapolation of alleged on-money receipts from shop sales based on loose papers found during search. The tribunal noted that sales manager A's statement denying receipt of on-money was not properly confronted with discrepancies, and no buyers were examined during search or assessment proceedings. Following precedents from Madras HC and Kerala HC, statements recorded under Section 133A lack evidentiary value. Without corroborating evidence, cash recovery, or buyer verification, the extrapolation for three assessment years was deemed unjustified. The tribunal emphasized that while search evidence can be used per Supreme Court's Pooran Mal ruling, it requires corroboration. Appeal partly allowed for all three years.
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