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 addressed unexplained investments during a search u/s 132. Nine wrist watches seized were deemed inadmissible under section 69, as they should have been evaluated under section 69A. Jewellery valued at Rs. 96,15,563/- was treated as explained, with the CIT(A)'s deletion of Rs. 1,07,22,844/- upheld. Regarding ownership of 6200 grams of jewellery, the tribunal directed the Assessing Officer to re-examine claimants' statements and verify ownership substantively. The presumption of ownership under section 132(4) remained rebuttable. The Revenue's appeal was partially allowed for statistical purposes, with specific directions for further investigation into the jewellery's provenance.
ITAT addressed unexplained investments during a search u/s 132. Nine wrist watches seized were deemed inadmissible under section 69, as they should have been evaluated under section 69A. Jewellery valued at Rs. 96,15,563/- was treated as explained, with the CIT(A)'s deletion of Rs. 1,07,22,844/- upheld. Regarding ownership of 6200 grams of jewellery, the tribunal directed the Assessing Officer to re-examine claimants' statements and verify ownership substantively. The presumption of ownership under section 132(4) remained rebuttable. The Revenue's appeal was partially allowed for statistical purposes, with specific directions for further investigation into the jewellery's provenance.
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