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 PCIT's revision order under s.263 regarding unaccounted cash purchases of Rs.5,83,99,000/-. The Tribunal held that where AO had already estimated profits on unaccounted cash purchases, additional disallowance under s.40A(3) was not warranted. Following established HC precedents, ITAT found AO's approach of applying gross profit estimation was a plausible view, precluding PCIT's revisionary powers. The assessment considering seized materials and ledger accounts demonstrated these were trading receipts during business operations. Since profits were already estimated and taxed on cash transactions, further disallowance under s.40A(3) was legally untenable. Assessee's appeals allowed, setting aside revision proceedings.
ITAT ruled against PCIT's revision order under s.263 regarding unaccounted cash purchases of Rs.5,83,99,000/-. The Tribunal held that where AO had already estimated profits on unaccounted cash purchases, additional disallowance under s.40A(3) was not warranted. Following established HC precedents, ITAT found AO's approach of applying gross profit estimation was a plausible view, precluding PCIT's revisionary powers. The assessment considering seized materials and ledger accounts demonstrated these were trading receipts during business operations. Since profits were already estimated and taxed on cash transactions, further disallowance under s.40A(3) was legally untenable. Assessee's appeals allowed, setting aside revision proceedings.
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