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 upheld multiple findings from CIT(A), predominantly favoring the assessee across various contested issues. Key determinations include deletion of additions under Section 68 relating to unexplained capital and cash credits, confirmation of jewellery valuation explanations, and rejection of revenue's extrapolation claims. The tribunal consistently applied precedential principles from the assessee's previous assessment year, dismissing revenue's appeals where no distinguishable facts or legal distinctions were presented. The ITAT directed the Assessing Officer to grant telescoping benefits against unaccounted income and investments, ultimately providing substantial relief to the assessee by substantially reducing proposed additions across different categories of income and investments.
ITAT upheld multiple findings from CIT(A), predominantly favoring the assessee across various contested issues. Key determinations include deletion of additions under Section 68 relating to unexplained capital and cash credits, confirmation of jewellery valuation explanations, and rejection of revenue's extrapolation claims. The tribunal consistently applied precedential principles from the assessee's previous assessment year, dismissing revenue's appeals where no distinguishable facts or legal distinctions were presented. The ITAT directed the Assessing Officer to grant telescoping benefits against unaccounted income and investments, ultimately providing substantial relief to the assessee by substantially reducing proposed additions across different categories of income and investments.
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