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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ITAT held in favor of the assessee, rejecting the Assessing Officer's (AO) arbitrary rejection of books of accounts. The tribunal found that the assessee provided comprehensive documentation, including audited financial statements, VAT and service tax returns, and stock registers. The AO's suspicion of sales during demonetization was deemed unjustified, particularly given the nature of the assessee's tobacco and perfumery products. The tribunal criticized the AO's approach of challenging cash sales without proper verification and noted inherent arbitrariness in partially accepting sales figures. Consequently, the tribunal deleted the impugned addition and allowed the assessee's appeal, emphasizing the need for substantive inquiry before challenging accounting records.
ITAT held in favor of the assessee, rejecting the Assessing Officer's (AO) arbitrary rejection of books of accounts. The tribunal found that the assessee provided comprehensive documentation, including audited financial statements, VAT and service tax returns, and stock registers. The AO's suspicion of sales during demonetization was deemed unjustified, particularly given the nature of the assessee's tobacco and perfumery products. The tribunal criticized the AO's approach of challenging cash sales without proper verification and noted inherent arbitrariness in partially accepting sales figures. Consequently, the tribunal deleted the impugned addition and allowed the assessee's appeal, emphasizing the need for substantive inquiry before challenging accounting records.
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