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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The ITAT ruled that the AO's addition under section 68 and denial of exemption under section 10(38) were untenable. The Tribunal found that the AO relied merely on assumptions from an Investigation Wing report without direct evidence, while ignoring evidence furnished by the assessee. Since the purchase of shares in an earlier year was accepted by revenue, and the sale occurred through the Stock Exchange with consideration received via banking channels, the sale proceeds could not be considered unexplained cash credits under section 68. Additionally, the ITAT deleted the disallowance under section 14A, noting that the AO failed to establish that investments were made using interest-bearing funds, making administrative expenditure disallowance impermissible.
The ITAT ruled that the AO's addition under section 68 and denial of exemption under section 10(38) were untenable. The Tribunal found that the AO relied merely on assumptions from an Investigation Wing report without direct evidence, while ignoring evidence furnished by the assessee. Since the purchase of shares in an earlier year was accepted by revenue, and the sale occurred through the Stock Exchange with consideration received via banking channels, the sale proceeds could not be considered unexplained cash credits under section 68. Additionally, the ITAT deleted the disallowance under section 14A, noting that the AO failed to establish that investments were made using interest-bearing funds, making administrative expenditure disallowance impermissible.
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