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 reversed AO's additions under s.68 for unexplained bank deposits, finding that while deposits were added as unexplained income, corresponding withdrawals from the same account were not considered in assessment. The tribunal held that additions were unsustainable given the pattern of deposits and withdrawals evidenced in bank statements. Additionally, penalty of Rs.10,000 imposed under s.271(1)(b) for non-appearance was deleted, as AO had provided unreasonably short notice period of one day for appearance. Both issues decided in favor of appellant, with tribunal emphasizing need to consider complete banking transaction patterns and provide reasonable compliance timeframes.
ITAT reversed AO's additions under s.68 for unexplained bank deposits, finding that while deposits were added as unexplained income, corresponding withdrawals from the same account were not considered in assessment. The tribunal held that additions were unsustainable given the pattern of deposits and withdrawals evidenced in bank statements. Additionally, penalty of Rs.10,000 imposed under s.271(1)(b) for non-appearance was deleted, as AO had provided unreasonably short notice period of one day for appearance. Both issues decided in favor of appellant, with tribunal emphasizing need to consider complete banking transaction patterns and provide reasonable compliance timeframes.
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