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 that the addition under Section 68 for unsecured loans was inappropriate. The tribunal found the assessee established creditor identity through PAN, creditworthiness via bank statements and ITRs, and confirmed loan origin from creditors' own bank accounts. The Assessing Officer's addition was based on mere suspicion without clinching evidence proving the funds did not genuinely belong to the stated creditors. The tribunal deleted the contested addition, ruling in favor of the assessee based on comprehensive documentary evidence demonstrating loan authenticity and creditor legitimacy.
ITAT held that the addition under Section 68 for unsecured loans was inappropriate. The tribunal found the assessee established creditor identity through PAN, creditworthiness via bank statements and ITRs, and confirmed loan origin from creditors' own bank accounts. The Assessing Officer's addition was based on mere suspicion without clinching evidence proving the funds did not genuinely belong to the stated creditors. The tribunal deleted the contested addition, ruling in favor of the assessee based on comprehensive documentary evidence demonstrating loan authenticity and creditor legitimacy.
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