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 overturned addition of unaccounted money allegedly received by assessee representing 20% of total consideration. Addition was based on extrapolation from loose papers discovered during search operations. Tribunal held that extrapolation for on-money receipts from shop sales cannot be sustained where no specific evidence was found during search, no proper investigation was conducted, and key witness was not questioned about incriminating documents. Additionally, many flats were sold to parties different from those listed in loose sheets, and buyers were unrelated parties. Given CIT(A) had already deleted similar additions for another partner in joint venture project Ganga Acropolis, ITAT deleted the disputed addition for AY 2017-18, ruling in assessee's favor.
ITAT overturned addition of unaccounted money allegedly received by assessee representing 20% of total consideration. Addition was based on extrapolation from loose papers discovered during search operations. Tribunal held that extrapolation for on-money receipts from shop sales cannot be sustained where no specific evidence was found during search, no proper investigation was conducted, and key witness was not questioned about incriminating documents. Additionally, many flats were sold to parties different from those listed in loose sheets, and buyers were unrelated parties. Given CIT(A) had already deleted similar additions for another partner in joint venture project Ganga Acropolis, ITAT deleted the disputed addition for AY 2017-18, ruling in assessee's favor.
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