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 held that additions made under Section 153A were improper where no incriminating material was discovered during search for the assessment year (AY 2013-14). The appellate tribunal determined that without specific incriminating evidence found during search proceedings, the Assessing Officer cannot make additions to completed assessments. The tribunal emphasized that stock statements from other years cannot be considered incriminating material, and since the assessee's opening stock was carried forward and explained, no additions under Sections 69 or 69B were warranted. The tribunal consequently set aside the additions made by the Assessing Officer as contrary to legal provisions and established judicial precedents.
ITAT held that additions made under Section 153A were improper where no incriminating material was discovered during search for the assessment year (AY 2013-14). The appellate tribunal determined that without specific incriminating evidence found during search proceedings, the Assessing Officer cannot make additions to completed assessments. The tribunal emphasized that stock statements from other years cannot be considered incriminating material, and since the assessee's opening stock was carried forward and explained, no additions under Sections 69 or 69B were warranted. The tribunal consequently set aside the additions made by the Assessing Officer as contrary to legal provisions and established judicial precedents.
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