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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT partially allowed the assessee's appeal, restricting unexplained cash deposit additions to Rs. 5 lakhs. The tribunal found no merit in the revenue department's contentions, noting that section 115BBE was inapplicable for FY 2016-17 transactions. The enhancement made by NFAC was quashed due to lack of opportunity of being heard. The tribunal concluded that cash sales were routine for a scrap dealer and the additions were not substantiated by cogent evidence. The AO was directed to delete balance additions beyond Rs. 5 lakhs, effectively providing partial relief to the assessee.
ITAT partially allowed the assessee's appeal, restricting unexplained cash deposit additions to Rs. 5 lakhs. The tribunal found no merit in the revenue department's contentions, noting that section 115BBE was inapplicable for FY 2016-17 transactions. The enhancement made by NFAC was quashed due to lack of opportunity of being heard. The tribunal concluded that cash sales were routine for a scrap dealer and the additions were not substantiated by cogent evidence. The AO was directed to delete balance additions beyond Rs. 5 lakhs, effectively providing partial relief to the assessee.
Note: It is a system-generated summary and is for quick reference only.