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 ruled against treating lease deposits and booking advances as cessation of liability under Section 41(1) of Income Tax Act. The 3 crore lease deposit was temporary, interest-free security for a 21-year lease period, properly documented and acknowledged. The 2.20 crore booking advances (1.20 crore opening balance plus 1 crore received) were standard business transactions through banking channels. AO failed to establish basic conditions for Section 41(1) or Section 68 applicability, as transactions predated AY 2020-21. The tribunal upheld CIT(A)'s deletion of additions, noting that mere doubts about transaction genuineness without substantive evidence cannot trigger Section 41(1) or 68. Ruling favored assessee, confirming deposits and advances remained valid liabilities.
ITAT ruled against treating lease deposits and booking advances as cessation of liability under Section 41(1) of Income Tax Act. The 3 crore lease deposit was temporary, interest-free security for a 21-year lease period, properly documented and acknowledged. The 2.20 crore booking advances (1.20 crore opening balance plus 1 crore received) were standard business transactions through banking channels. AO failed to establish basic conditions for Section 41(1) or Section 68 applicability, as transactions predated AY 2020-21. The tribunal upheld CIT(A)'s deletion of additions, noting that mere doubts about transaction genuineness without substantive evidence cannot trigger Section 41(1) or 68. Ruling favored assessee, confirming deposits and advances remained valid liabilities.
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