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 in favor of the assessee regarding additions made under section 153C based on entries in "Hazir Johri" software discovered during a search of JBL. While the AO relied on a director's statement confirming the software documented both official and unofficial transactions, the Tribunal found no concrete evidence linking the assessee to transactions in the combined ledger. The revenue failed to produce corroborative evidence such as bills, vouchers, or stock registers to establish the nature of transactions or prove cash sales belonged to the assessee. Following precedents in Anoop Kumar Soni and Surender Kumar Jain cases involving similar JBL search matters, the Tribunal concluded that entries in the software alone were insufficient for making additions.
The ITAT ruled in favor of the assessee regarding additions made under section 153C based on entries in "Hazir Johri" software discovered during a search of JBL. While the AO relied on a director's statement confirming the software documented both official and unofficial transactions, the Tribunal found no concrete evidence linking the assessee to transactions in the combined ledger. The revenue failed to produce corroborative evidence such as bills, vouchers, or stock registers to establish the nature of transactions or prove cash sales belonged to the assessee. Following precedents in Anoop Kumar Soni and Surender Kumar Jain cases involving similar JBL search matters, the Tribunal concluded that entries in the software alone were insufficient for making additions.
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