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 additions under s.69A r.w.s. 115BBE regarding cash deposits made during demonetization period. The taxpayer successfully demonstrated that deposits originated from legitimate cash sales recorded in books of accounts and verified by statutory authorities. ITAT found that cash generated through sales was properly credited in books and supported by TNVAT records and chartered accountant audit. The AO's allegations of abnormal sales patterns were rejected as based merely on suspicion without concrete evidence. Double taxation was deemed impermissible since sales were already reflected in accounts and offered for tax. The Tribunal concluded s.69A provisions were inapplicable as source of deposits was satisfactorily explained through documented business transactions.
ITAT upheld deletion of additions under s.69A r.w.s. 115BBE regarding cash deposits made during demonetization period. The taxpayer successfully demonstrated that deposits originated from legitimate cash sales recorded in books of accounts and verified by statutory authorities. ITAT found that cash generated through sales was properly credited in books and supported by TNVAT records and chartered accountant audit. The AO's allegations of abnormal sales patterns were rejected as based merely on suspicion without concrete evidence. Double taxation was deemed impermissible since sales were already reflected in accounts and offered for tax. The Tribunal concluded s.69A provisions were inapplicable as source of deposits was satisfactorily explained through documented business transactions.
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