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 multiple tax-related issues for the assessee. Key outcomes include: (1) Bogus purchases disallowed at 50%; (2) On-money receipts remanded to AO for reassessment at 10% with expense set-off; (3) Cash interest payments disallowed under section 40A(3); (4) Unexplained cash deposits and ITS data-based additions largely rejected; (5) Disallowance under section 14A restricted to exempt income; (6) Salary paid to director's non-working wife disallowed. The Tribunal largely upheld the AO's assessments with partial relief, maintaining the principle of strict scrutiny of unexplained financial transactions and adherence to tax regulations.
ITAT adjudicated multiple tax-related issues for the assessee. Key outcomes include: (1) Bogus purchases disallowed at 50%; (2) On-money receipts remanded to AO for reassessment at 10% with expense set-off; (3) Cash interest payments disallowed under section 40A(3); (4) Unexplained cash deposits and ITS data-based additions largely rejected; (5) Disallowance under section 14A restricted to exempt income; (6) Salary paid to director's non-working wife disallowed. The Tribunal largely upheld the AO's assessments with partial relief, maintaining the principle of strict scrutiny of unexplained financial transactions and adherence to tax regulations.
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