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 allowed taxpayer's appeal, finding cash payments for land purchase were genuine business transactions. The tribunal determined payments were made out of commercial necessity and complied with Rule 6DD exceptions. Cash deposits during demonetization were substantiated through assessee's cash book, which demonstrated advances against land/plot purchases. The appellate tribunal set aside the lower authority's order, directing the AO to delete the tax addition, effectively vindicating the taxpayer's accounting practices and validating the cash transactions as legitimate business expenditures.
ITAT allowed taxpayer's appeal, finding cash payments for land purchase were genuine business transactions. The tribunal determined payments were made out of commercial necessity and complied with Rule 6DD exceptions. Cash deposits during demonetization were substantiated through assessee's cash book, which demonstrated advances against land/plot purchases. The appellate tribunal set aside the lower authority's order, directing the AO to delete the tax addition, effectively vindicating the taxpayer's accounting practices and validating the cash transactions as legitimate business expenditures.
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