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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT deleted additions under s.69B for alleged cash payment for old machinery purchase, finding the printout was not a "speaking document" that could sustain charges without corroborative evidence. The tribunal noted M/s Chetak Enterprises denied receiving cash, and the machinery's market value aligned with the valuation report. Similarly, additions under s.69C for alleged cash payments to suppliers were deleted as there was no admission of cash transactions from either the appellant or recipients, with evidence showing payments were made through banking channels. The ITAT criticized the AO for failing to gather corroborative evidence or allowing cross-examination of the alleged recipients, concluding there was no justification for sustaining either addition.
ITAT deleted additions under s.69B for alleged cash payment for old machinery purchase, finding the printout was not a "speaking document" that could sustain charges without corroborative evidence. The tribunal noted M/s Chetak Enterprises denied receiving cash, and the machinery's market value aligned with the valuation report. Similarly, additions under s.69C for alleged cash payments to suppliers were deleted as there was no admission of cash transactions from either the appellant or recipients, with evidence showing payments were made through banking channels. The ITAT criticized the AO for failing to gather corroborative evidence or allowing cross-examination of the alleged recipients, concluding there was no justification for sustaining either addition.
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