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 HC held that the seized cash was properly assessed as unaccounted money under section 69A read with section 115BBE. Despite the appellant's declaration during search operations that the money represented commission income, the court found this mere assertion insufficient without satisfactory explanation supported by material evidence. The appellants' failure to respond to show cause notices demonstrated indifference. The court emphasized that even when an explanation is provided, it must satisfy the Assessing Officer as required by section 69A. Following Shashi Garg, the court affirmed that the burden to explain cash sources rests with the assessee, and this burden was not discharged. The appeal was dismissed.
The HC held that the seized cash was properly assessed as unaccounted money under section 69A read with section 115BBE. Despite the appellant's declaration during search operations that the money represented commission income, the court found this mere assertion insufficient without satisfactory explanation supported by material evidence. The appellants' failure to respond to show cause notices demonstrated indifference. The court emphasized that even when an explanation is provided, it must satisfy the Assessing Officer as required by section 69A. Following Shashi Garg, the court affirmed that the burden to explain cash sources rests with the assessee, and this burden was not discharged. The appeal was dismissed.
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