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 on unexplained purchases under s.69C and unaccounted sales. For unexplained purchases in non-edible oil business, ITAT directed estimation of profit at 8% based on industry GP rates and assessee's past performance (weighted average GP of 7.96% during AY 2014-18). Regarding unaccounted sales addition based on seized Shubh Laxmi Group documents, ITAT rejected AO's addition since statement of witness was used without providing cross-examination opportunity, violating natural justice principles. Further, AO had already made additions for unaccounted purchases and short stock as unaccounted sales, making separate sales addition unjustified. ITAT emphasized past trading history as key determinant and applied doctrine of equity in profit estimation.
ITAT ruled on unexplained purchases under s.69C and unaccounted sales. For unexplained purchases in non-edible oil business, ITAT directed estimation of profit at 8% based on industry GP rates and assessee's past performance (weighted average GP of 7.96% during AY 2014-18). Regarding unaccounted sales addition based on seized Shubh Laxmi Group documents, ITAT rejected AO's addition since statement of witness was used without providing cross-examination opportunity, violating natural justice principles. Further, AO had already made additions for unaccounted purchases and short stock as unaccounted sales, making separate sales addition unjustified. ITAT emphasized past trading history as key determinant and applied doctrine of equity in profit estimation.
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