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 Revenue's addition under s153A for alleged bogus purchases. Assessment was based solely on pre-search statements from ML and DK without supporting incriminating materials discovered during search operations. Assessee provided complete quantitative details backed by tax audit reports, with no discrepancies except statements and STRs from Investigation Wing. Tribunal emphasized that circumstantial evidence and statements alone cannot constitute incriminating material without corroborative proof. Mere reliance on statements recorded prior to search, without additional evidence gathered during search proceedings, failed to establish bogus purchases. Assessment order quashed due to lack of incriminating material found during search.
ITAT ruled against Revenue's addition under s153A for alleged bogus purchases. Assessment was based solely on pre-search statements from ML and DK without supporting incriminating materials discovered during search operations. Assessee provided complete quantitative details backed by tax audit reports, with no discrepancies except statements and STRs from Investigation Wing. Tribunal emphasized that circumstantial evidence and statements alone cannot constitute incriminating material without corroborative proof. Mere reliance on statements recorded prior to search, without additional evidence gathered during search proceedings, failed to establish bogus purchases. Assessment order quashed due to lack of incriminating material found during search.
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