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 examined three key issues regarding property transactions and unexplained funds. On unexplained money under s.69A, the Tribunal upheld CIT(A)'s deletion of AO's addition, finding sufficient evidence for property acquisition. However, the short-term capital loss claim was rejected as it wasn't declared in the original return per s.80. Regarding unexplained investment, ITAT confirmed deletion of addition as payments were through banking channels with substantiated sources, except for INR 32.5 Lakhs stamp duty payment which was remanded for AO verification. On cash deposits, ITAT ruled AO exceeded limited scrutiny scope by examining bank deposits not included in original assessment reasons, and found sufficient cash balance explanation, thereby deleting the addition.
ITAT examined three key issues regarding property transactions and unexplained funds. On unexplained money under s.69A, the Tribunal upheld CIT(A)'s deletion of AO's addition, finding sufficient evidence for property acquisition. However, the short-term capital loss claim was rejected as it wasn't declared in the original return per s.80. Regarding unexplained investment, ITAT confirmed deletion of addition as payments were through banking channels with substantiated sources, except for INR 32.5 Lakhs stamp duty payment which was remanded for AO verification. On cash deposits, ITAT ruled AO exceeded limited scrutiny scope by examining bank deposits not included in original assessment reasons, and found sufficient cash balance explanation, thereby deleting the addition.
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