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 upheld CIT(A)'s deletion of additions made under s.69A r.w.s. 115BBE regarding unexplained cash deposits during demonetization. The assessee successfully demonstrated that cash deposits originated from legitimate sales recorded in books of accounts and already subjected to taxation. The tribunal noted that only 17.50% of pre-demonetization stock was sold on 08.11.2016, rejecting AO's allegations of abnormal sales as unsupported by evidence. ITAT emphasized that additions cannot be sustained merely on suspicion or conjecture, particularly when cash from sales was properly recorded in books. Double taxation being impermissible, s.69A provisions were deemed inapplicable as the source of deposits was adequately explained and documented.
ITAT upheld CIT(A)'s deletion of additions made under s.69A r.w.s. 115BBE regarding unexplained cash deposits during demonetization. The assessee successfully demonstrated that cash deposits originated from legitimate sales recorded in books of accounts and already subjected to taxation. The tribunal noted that only 17.50% of pre-demonetization stock was sold on 08.11.2016, rejecting AO's allegations of abnormal sales as unsupported by evidence. ITAT emphasized that additions cannot be sustained merely on suspicion or conjecture, particularly when cash from sales was properly recorded in books. Double taxation being impermissible, s.69A provisions were deemed inapplicable as the source of deposits was adequately explained and documented.
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