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 deletion of addition under section 68 regarding unexplained share application money and premium. Assessee established initial burden of proof through banking channel transactions. While AO confirmed service of section 133(6) notices to investor companies, subsequent doubts about company addresses based on IT Inspector's inquiry lacked specific inspection dates. AO failed to produce concrete evidence disproving transaction genuineness or demonstrating undisclosed income. Non-appearance of investor company directors alone insufficient to invalidate transactions. ITAT found CIT(A)'s deletion of addition justified as assessee satisfied section 68 requirements through proper documentation and banking records. Revenue's appeal dismissed.
ITAT upheld deletion of addition under section 68 regarding unexplained share application money and premium. Assessee established initial burden of proof through banking channel transactions. While AO confirmed service of section 133(6) notices to investor companies, subsequent doubts about company addresses based on IT Inspector's inquiry lacked specific inspection dates. AO failed to produce concrete evidence disproving transaction genuineness or demonstrating undisclosed income. Non-appearance of investor company directors alone insufficient to invalidate transactions. ITAT found CIT(A)'s deletion of addition justified as assessee satisfied section 68 requirements through proper documentation and banking records. Revenue's appeal dismissed.
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