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 held that the assessee successfully discharged the onus of establishing purchase genuineness by providing comprehensive documentary evidence including invoices, goods receipt notes, transport bills, and weighing bridge slips. Despite some procedural discrepancies and non-response to section 133(6) notices by certain parties, the tribunal affirmed that these factors do not automatically render transactions as bogus. The CIT(A)'s deletion of additions was upheld, and the revenue's appeal was dismissed, reinforcing the principle that mere procedural irregularities cannot invalidate legitimate business transactions when substantive evidence supports their authenticity.
ITAT held that the assessee successfully discharged the onus of establishing purchase genuineness by providing comprehensive documentary evidence including invoices, goods receipt notes, transport bills, and weighing bridge slips. Despite some procedural discrepancies and non-response to section 133(6) notices by certain parties, the tribunal affirmed that these factors do not automatically render transactions as bogus. The CIT(A)'s deletion of additions was upheld, and the revenue's appeal was dismissed, reinforcing the principle that mere procedural irregularities cannot invalidate legitimate business transactions when substantive evidence supports their authenticity.
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