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...
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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 appellant's appeal, deleting three additions made by the AO. Regarding unexplained cash under s.69A, the Tribunal held that a statement made during search, though important evidence, is not conclusive and can be retracted. For the silver jewelry addition, the Bench found the AO failed to make proper inquiries despite documentary evidence of approval stock being available. Concerning the alleged excess 18-carat gold jewelry and shortage of 22-carat items, ITAT determined this discrepancy resulted from improper segregation during valuation when tags became jumbled. The negligible weight difference between book records and physical inventory, supported by day-to-day stock registers, justified deletion of these additions.
The ITAT allowed the appellant's appeal, deleting three additions made by the AO. Regarding unexplained cash under s.69A, the Tribunal held that a statement made during search, though important evidence, is not conclusive and can be retracted. For the silver jewelry addition, the Bench found the AO failed to make proper inquiries despite documentary evidence of approval stock being available. Concerning the alleged excess 18-carat gold jewelry and shortage of 22-carat items, ITAT determined this discrepancy resulted from improper segregation during valuation when tags became jumbled. The negligible weight difference between book records and physical inventory, supported by day-to-day stock registers, justified deletion of these additions.
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