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 upheld the reopening of assessment under s.147 as it was based on new facts not previously available to the AO, rejecting assessee's claim of mere "change of opinion." Regarding bogus purchases from six entities, ITAT confirmed CIT(A)'s approach of quantifying profit at 10% GP rate (less 1.53% already disclosed), sustaining addition of Rs. 1,22,08,002. CIT(A) reasonably estimated profits based on prevailing GP rates in rice miller/trader business for goods procured from grey market rather than bogus entities. On unaccounted investments, ITAT affirmed AO's addition based on "peak purchase" amount appearing in bogus concern's account, considering it represented unexplained investment in bogus billing operations.
ITAT upheld the reopening of assessment under s.147 as it was based on new facts not previously available to the AO, rejecting assessee's claim of mere "change of opinion." Regarding bogus purchases from six entities, ITAT confirmed CIT(A)'s approach of quantifying profit at 10% GP rate (less 1.53% already disclosed), sustaining addition of Rs. 1,22,08,002. CIT(A) reasonably estimated profits based on prevailing GP rates in rice miller/trader business for goods procured from grey market rather than bogus entities. On unaccounted investments, ITAT affirmed AO's addition based on "peak purchase" amount appearing in bogus concern's account, considering it represented unexplained investment in bogus billing operations.
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