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 additions made by the AO based solely on credits in the non-resident assessee's NRE accounts were unsustainable without establishing that the original source of funds was taxable in India. Following precedents in Nitin Mavji Vekariya and Bhavesh Chandrakantbhai Bhatt, the Tribunal held that NRE deposits from foreign remittances are exempt under s.10(4). For AY 2013-14, the HSBC Bank (NRE) addition was deleted as it represented redemption of an NRE fixed deposit, while HDFC and Deutsche Bank additions were remanded for verification of source. For AY 2015-16, the HDFC Bank (NRE) addition was deleted as it constituted an inward remittance from JP Morgan Chase Bank, UK. The appeal was partly allowed with directions for further verification.
The ITAT ruled that additions made by the AO based solely on credits in the non-resident assessee's NRE accounts were unsustainable without establishing that the original source of funds was taxable in India. Following precedents in Nitin Mavji Vekariya and Bhavesh Chandrakantbhai Bhatt, the Tribunal held that NRE deposits from foreign remittances are exempt under s.10(4). For AY 2013-14, the HSBC Bank (NRE) addition was deleted as it represented redemption of an NRE fixed deposit, while HDFC and Deutsche Bank additions were remanded for verification of source. For AY 2015-16, the HDFC Bank (NRE) addition was deleted as it constituted an inward remittance from JP Morgan Chase Bank, UK. The appeal was partly allowed with directions for further verification.
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