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 upheld the CIT(A)'s decision to reject the assessee's books of accounts under section 145 and estimate income under section 144. The Tribunal clarified that when income is estimated through best judgment assessment, such estimate substitutes the business income computation under sections 30-43D as prescribed by section 29. All deductions referenced in sections 30-43D are deemed incorporated within this estimate. The Tribunal rejected the Revenue's plea, finding no infirmity in the CIT(A)'s approach of rejecting the books and estimating total income based on best judgment assessment principles.
The ITAT upheld the CIT(A)'s decision to reject the assessee's books of accounts under section 145 and estimate income under section 144. The Tribunal clarified that when income is estimated through best judgment assessment, such estimate substitutes the business income computation under sections 30-43D as prescribed by section 29. All deductions referenced in sections 30-43D are deemed incorporated within this estimate. The Tribunal rejected the Revenue's plea, finding no infirmity in the CIT(A)'s approach of rejecting the books and estimating total income based on best judgment assessment principles.
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