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 quashed the assessment proceedings due to jurisdictional defects in the notice under section 148. The ITO, Nabha incorrectly issued the notice when jurisdiction properly belonged to ACIT/DCIT, Mandi Gobindgarh. When the file was transferred, ACIT/DCIT failed to issue a fresh notice, rendering the proceedings legally invalid. On merits, the Tribunal also found the addition of Rs. 12,39,90,680/- as unexplained cash credits unjustified, as the assessee had demonstrated that deposits originated from legitimate sales of Harvester Combines and spares, supported by proper documentation including ledger accounts, sale invoices, and trading accounts. Following the principle in Ludhiana Steel Rolling Mills, such additions were impermissible when books of accounts had not been rejected. Appeal allowed.
The ITAT quashed the assessment proceedings due to jurisdictional defects in the notice under section 148. The ITO, Nabha incorrectly issued the notice when jurisdiction properly belonged to ACIT/DCIT, Mandi Gobindgarh. When the file was transferred, ACIT/DCIT failed to issue a fresh notice, rendering the proceedings legally invalid. On merits, the Tribunal also found the addition of Rs. 12,39,90,680/- as unexplained cash credits unjustified, as the assessee had demonstrated that deposits originated from legitimate sales of Harvester Combines and spares, supported by proper documentation including ledger accounts, sale invoices, and trading accounts. Following the principle in Ludhiana Steel Rolling Mills, such additions were impermissible when books of accounts had not been rejected. Appeal allowed.
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