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 rejected revenue's appeal, affirming CIT(A)'s findings across multiple grounds. The tribunal dismissed revenue's challenges regarding income estimation, book of accounts rejection, and profit rate determination. Key holdings included: (1) When books are rejected and net profit estimated, no further additions can be made from the same rejected books, (2) Only real income should be taxed, not notional income, (3) Differences in form 26AS and book entries were adequately explained, and (4) The profit rate of 0.11% was consistent with coordinated bench precedent. The tribunal found no merit in revenue's grounds and dismissed all appeals, maintaining the lower appellate authority's favorable findings for the assessee.
The ITAT rejected revenue's appeal, affirming CIT(A)'s findings across multiple grounds. The tribunal dismissed revenue's challenges regarding income estimation, book of accounts rejection, and profit rate determination. Key holdings included: (1) When books are rejected and net profit estimated, no further additions can be made from the same rejected books, (2) Only real income should be taxed, not notional income, (3) Differences in form 26AS and book entries were adequately explained, and (4) The profit rate of 0.11% was consistent with coordinated bench precedent. The tribunal found no merit in revenue's grounds and dismissed all appeals, maintaining the lower appellate authority's favorable findings for the assessee.
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