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 the addition to income based on search operation surrender cannot be sustained. No incriminating material was found during search and seizure action at assessee's premises. The statement under Section 132(4) was retracted with detailed explanations, and seized documents did not reveal any undisclosed transactions. The Assessing Officer cannot make additions solely on an unsupported alleged surrender, especially when no evidence substantiates the claim. Under the new legal framework for search assessments, incriminating material is mandatory for reopening assessments beyond three years. The tribunal ruled in favor of the assessee, effectively rejecting the revenue's proposed income addition.
ITAT held that the addition to income based on search operation surrender cannot be sustained. No incriminating material was found during search and seizure action at assessee's premises. The statement under Section 132(4) was retracted with detailed explanations, and seized documents did not reveal any undisclosed transactions. The Assessing Officer cannot make additions solely on an unsupported alleged surrender, especially when no evidence substantiates the claim. Under the new legal framework for search assessments, incriminating material is mandatory for reopening assessments beyond three years. The tribunal ruled in favor of the assessee, effectively rejecting the revenue's proposed income addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
