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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT reversed the addition made by AO under section 69 for unexplained investment. The addition was based solely on an excel sheet found at a third party's premises, which allegedly showed cash loans advanced by the appellant. The Tribunal held that the excel sheet alone was insufficient evidence as it was neither authored by nor found in possession of the appellant. Without corroborative evidence establishing the appellant's connection to the alleged transactions, the addition was unsustainable. Following precedents in Appu Direct Pvt Ltd and Sant Lal, ITAT affirmed that liability cannot be fastened based solely on third-party materials without supporting evidence. The CIT(A)'s deletion of the addition was upheld.
ITAT reversed the addition made by AO under section 69 for unexplained investment. The addition was based solely on an excel sheet found at a third party's premises, which allegedly showed cash loans advanced by the appellant. The Tribunal held that the excel sheet alone was insufficient evidence as it was neither authored by nor found in possession of the appellant. Without corroborative evidence establishing the appellant's connection to the alleged transactions, the addition was unsustainable. Following precedents in Appu Direct Pvt Ltd and Sant Lal, ITAT affirmed that liability cannot be fastened based solely on third-party materials without supporting evidence. The CIT(A)'s deletion of the addition was upheld.
Note: It is a system-generated summary and is for quick reference only.