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 upheld the lower authorities' findings in tax assessment proceedings u/s 153A for AY 2011-12 to 2019-20. The tribunal dismissed the assessee's contentions challenging the consolidated order, following precedent in Hitesh Golecha case. The tribunal confirmed additions of unaccounted income by estimating gross profit at 8% and commission at 1% on undisclosed sales. The order was based on the assessee's failure to provide plausible explanations and evasive conduct during proceedings. No substantial legal infirmity was found in the CIT(A)'s order, and the tribunal upheld the assessment order as legally valid.
ITAT upheld the lower authorities' findings in tax assessment proceedings u/s 153A for AY 2011-12 to 2019-20. The tribunal dismissed the assessee's contentions challenging the consolidated order, following precedent in Hitesh Golecha case. The tribunal confirmed additions of unaccounted income by estimating gross profit at 8% and commission at 1% on undisclosed sales. The order was based on the assessee's failure to provide plausible explanations and evasive conduct during proceedings. No substantial legal infirmity was found in the CIT(A)'s order, and the tribunal upheld the assessment order as legally valid.
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