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 allowed the assessee's appeal against additions made under the Black Money Act regarding foreign bank accounts. The Tribunal found that the accounts were opened and operated by the assessee's parents during their lifetime, with deposits made prior to 2010. Evidence confirmed the father conducted business in Sudan under the trade name "BABU" and the mother independently managed financial affairs as shown by passport entries. The ITAT recognized the inherent difficulty for the assessee to provide complete documentation for transactions managed by deceased parents. Since the deposits originated from income earned abroad by the parents, not from undisclosed Indian income, the Tribunal concluded the Black Money Act was inapplicable and directed deletion of the additions.
The ITAT allowed the assessee's appeal against additions made under the Black Money Act regarding foreign bank accounts. The Tribunal found that the accounts were opened and operated by the assessee's parents during their lifetime, with deposits made prior to 2010. Evidence confirmed the father conducted business in Sudan under the trade name "BABU" and the mother independently managed financial affairs as shown by passport entries. The ITAT recognized the inherent difficulty for the assessee to provide complete documentation for transactions managed by deceased parents. Since the deposits originated from income earned abroad by the parents, not from undisclosed Indian income, the Tribunal concluded the Black Money Act was inapplicable and directed deletion of the additions.
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