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 remanded matters concerning discrepancies between Form 26AS receipts and ITR, and rejection of trading results back to AO for de novo consideration. Assessee failed to adequately explain mobilization advances and reconciliation differences. CIT(A)'s order was deemed cryptic and non-speaking regarding GP ratio mismatch. AO directed to re-examine gross profit after assessee provides documentary evidence. Assessee bears responsibility to substantiate claims during consequential proceedings. If assessee fails to respond to notices or provide required documentation, AO empowered to adjudicate based on available facts and law. Revenue's grounds allowed for statistical purposes.
ITAT remanded matters concerning discrepancies between Form 26AS receipts and ITR, and rejection of trading results back to AO for de novo consideration. Assessee failed to adequately explain mobilization advances and reconciliation differences. CIT(A)'s order was deemed cryptic and non-speaking regarding GP ratio mismatch. AO directed to re-examine gross profit after assessee provides documentary evidence. Assessee bears responsibility to substantiate claims during consequential proceedings. If assessee fails to respond to notices or provide required documentation, AO empowered to adjudicate based on available facts and law. Revenue's grounds allowed for statistical purposes.
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