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 dismissed revenue appeals concerning alleged suppression of sales and inflated commission expenditure. Regarding sales suppression, the Tribunal found the addition unjustified as the AO failed to establish how electronic sales could be deposited into separate bank accounts, never provided IATA data to the assessee for verification, and misunderstood Agency Debit Memo as income rather than expense. The AO relied solely on an appraisal report without independent investigation or providing computation methods. Concerning commission expenditure, the ITAT upheld CIT(A)'s deletion of additions, noting the AO arbitrarily set 10% as reasonable without justification, failed to challenge payment genuineness, and disregarded business prudence from the assessee's perspective as established in Dhanrajgiri Raja Narasingirji.
The ITAT dismissed revenue appeals concerning alleged suppression of sales and inflated commission expenditure. Regarding sales suppression, the Tribunal found the addition unjustified as the AO failed to establish how electronic sales could be deposited into separate bank accounts, never provided IATA data to the assessee for verification, and misunderstood Agency Debit Memo as income rather than expense. The AO relied solely on an appraisal report without independent investigation or providing computation methods. Concerning commission expenditure, the ITAT upheld CIT(A)'s deletion of additions, noting the AO arbitrarily set 10% as reasonable without justification, failed to challenge payment genuineness, and disregarded business prudence from the assessee's perspective as established in Dhanrajgiri Raja Narasingirji.
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