Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT overturned multiple additions made by AO regarding property transactions and unexplained cash receipts. On capital gains computation under s.50C, ITAT directed matter to DVO for fair market value determination, as circle rate adoption was disputed. Addition for alleged cash receipt was deleted due to lack of evidence and timing of property registration falling in subsequent assessment year. Regarding construction costs, cash flow statement requires AO's factual examination. Additions based on loose slips were deleted as documents lacked dates and definitive connection to assessment year. For s.68 addition concerning loan transaction, matter restored to AO for de novo adjudication considering assessee's explanation about generator sale. ITAT emphasized need for proper verification and evidence before making additions.
ITAT overturned multiple additions made by AO regarding property transactions and unexplained cash receipts. On capital gains computation under s.50C, ITAT directed matter to DVO for fair market value determination, as circle rate adoption was disputed. Addition for alleged cash receipt was deleted due to lack of evidence and timing of property registration falling in subsequent assessment year. Regarding construction costs, cash flow statement requires AO's factual examination. Additions based on loose slips were deleted as documents lacked dates and definitive connection to assessment year. For s.68 addition concerning loan transaction, matter restored to AO for de novo adjudication considering assessee's explanation about generator sale. ITAT emphasized need for proper verification and evidence before making additions.
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