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 partially allowed the appeal concerning unexplained cash credits under Section 68. The Tribunal deleted additions of 1.57 crore cash deposit in Andhra Bank, accepting assessee's explanation regarding property transaction supported by sale-purchase deed. Cash deposits in Chartered Sahakari and Karnataka State Apex Co-operative Banks were justified through documented withdrawals and property sale proceeds. Addition of 10 lakh from KR Shelter was confirmed as assessee failed to substantiate its accounting treatment. ITAT deleted addition of 2.45 lakh alleged as interest income, concluding it represented an instrument transaction rather than interest credit. The Tribunal emphasized the common practice of oral agreements in real estate transactions and noted Revenue's failure to conduct independent inquiries despite available details.
ITAT partially allowed the appeal concerning unexplained cash credits under Section 68. The Tribunal deleted additions of 1.57 crore cash deposit in Andhra Bank, accepting assessee's explanation regarding property transaction supported by sale-purchase deed. Cash deposits in Chartered Sahakari and Karnataka State Apex Co-operative Banks were justified through documented withdrawals and property sale proceeds. Addition of 10 lakh from KR Shelter was confirmed as assessee failed to substantiate its accounting treatment. ITAT deleted addition of 2.45 lakh alleged as interest income, concluding it represented an instrument transaction rather than interest credit. The Tribunal emphasized the common practice of oral agreements in real estate transactions and noted Revenue's failure to conduct independent inquiries despite available details.
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