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 invalidated digital evidence seized during a search operation, specifically a pendrive, as inadmissible under Section 65B of the Indian Evidence Act. The Tribunal held that any details extracted from unsustainable digital evidence cannot be used for making tax additions. Consequently, the Assessing Officer's reliance on an unaccounted cash book was rejected due to lack of corroborating material. The Tribunal deleted the interest payment addition, ruling in favor of the assessee and emphasizing the strict requirements for digital evidence admissibility in tax proceedings.
The ITAT invalidated digital evidence seized during a search operation, specifically a pendrive, as inadmissible under Section 65B of the Indian Evidence Act. The Tribunal held that any details extracted from unsustainable digital evidence cannot be used for making tax additions. Consequently, the Assessing Officer's reliance on an unaccounted cash book was rejected due to lack of corroborating material. The Tribunal deleted the interest payment addition, ruling in favor of the assessee and emphasizing the strict requirements for digital evidence admissibility in tax proceedings.
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