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 CIT(A)'s finding regarding unaccounted sales, dismissing Revenue's appeal. The tribunal determined that a substantial portion of allegedly unaccounted sales were already recorded in the assessee's books. Given the minimal volume of transactions with the specific party and verified accounting, the tribunal concluded that only the gross profit rate could be applied to potentially unaccounted sales. The decision emphasized that without challenging purchase records, entire sales cannot be summarily added as unaccounted. Consequently, the tribunal applied the disclosed gross profit rate reasonably and rejected the Revenue's broader claim of complete sales addition.
ITAT upheld CIT(A)'s finding regarding unaccounted sales, dismissing Revenue's appeal. The tribunal determined that a substantial portion of allegedly unaccounted sales were already recorded in the assessee's books. Given the minimal volume of transactions with the specific party and verified accounting, the tribunal concluded that only the gross profit rate could be applied to potentially unaccounted sales. The decision emphasized that without challenging purchase records, entire sales cannot be summarily added as unaccounted. Consequently, the tribunal applied the disclosed gross profit rate reasonably and rejected the Revenue's broader claim of complete sales addition.
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