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 adjudicated a tax dispute involving unaccounted business receipts. The tribunal upheld the assessee's declaration of on-money receipts, finding the income component was based on seized material and properly explained during assessment proceedings. The ITAT rejected revenue's attempts to make protective additions and disallow expenditures, noting that the expenses were not prohibited by law and the income was fairly computed. The tribunal found no substantive reason to interfere with the lower appellate authority's findings, thereby dismissing revenue's grounds of appeal and maintaining the assessee's tax treatment of the contested receipts and expenditures.
ITAT adjudicated a tax dispute involving unaccounted business receipts. The tribunal upheld the assessee's declaration of on-money receipts, finding the income component was based on seized material and properly explained during assessment proceedings. The ITAT rejected revenue's attempts to make protective additions and disallow expenditures, noting that the expenses were not prohibited by law and the income was fairly computed. The tribunal found no substantive reason to interfere with the lower appellate authority's findings, thereby dismissing revenue's grounds of appeal and maintaining the assessee's tax treatment of the contested receipts and expenditures.
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