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 allowed the assessee's appeal, rejecting the lower authorities' attempt to disallow books of accounts under section 145(3). The tribunal found no substantive defects in the maintained records and determined that rejection was based on mere conjecture, not concrete evidence. The decision emphasized that the assessee's books were regularly audited, with no significant discrepancies. The tribunal critically noted the revenue's failure to demonstrate improper accounting, particularly regarding the commission agent's business operations. Consequently, the tribunal deleted the estimated profit additions and upheld the assessee's original financial reporting, affirming the integrity of the submitted accounts.
ITAT allowed the assessee's appeal, rejecting the lower authorities' attempt to disallow books of accounts under section 145(3). The tribunal found no substantive defects in the maintained records and determined that rejection was based on mere conjecture, not concrete evidence. The decision emphasized that the assessee's books were regularly audited, with no significant discrepancies. The tribunal critically noted the revenue's failure to demonstrate improper accounting, particularly regarding the commission agent's business operations. Consequently, the tribunal deleted the estimated profit additions and upheld the assessee's original financial reporting, affirming the integrity of the submitted accounts.
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