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 allowed taxpayer's appeal against additions made for unexplained cash and jewelry found during search proceedings. The Tribunal held that mere possession of cash withdrawn from business cannot be treated as unexplained when no contrary evidence exists showing its utilization elsewhere. Regarding jewelry, ITAT ruled that items found in Nidhi Data's bedroom and locker, supported by evidence and affidavits, cannot be treated as unexplained assets in assessee's hands. Similarly, silver articles discovered in Nidhi Data's possession were deemed justified given the family's status and absence of any purchase evidence during search. The Tribunal directed deletion of additions totaling Rs. 27,15,544 for gold jewelry and reversed the finding on unexplained silver articles.
ITAT allowed taxpayer's appeal against additions made for unexplained cash and jewelry found during search proceedings. The Tribunal held that mere possession of cash withdrawn from business cannot be treated as unexplained when no contrary evidence exists showing its utilization elsewhere. Regarding jewelry, ITAT ruled that items found in Nidhi Data's bedroom and locker, supported by evidence and affidavits, cannot be treated as unexplained assets in assessee's hands. Similarly, silver articles discovered in Nidhi Data's possession were deemed justified given the family's status and absence of any purchase evidence during search. The Tribunal directed deletion of additions totaling Rs. 27,15,544 for gold jewelry and reversed the finding on unexplained silver articles.
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