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 AO's reopening of assessment based on suspicion of fictitious trades in illiquid options derivatives was unsubstantiated. The tribunal found no evidence of fraudulent transactions, noting that trading in thinly traded stock options was not inherently unusual, especially given stock exchange incentive schemes. The tribunal determined the assessee's trades were genuine during the specified period. Consequently, the tribunal deleted the disallowed loss and allowed the assessee's appeal, emphasizing the need for concrete evidence before challenging legitimate trading activities.
ITAT held that the AO's reopening of assessment based on suspicion of fictitious trades in illiquid options derivatives was unsubstantiated. The tribunal found no evidence of fraudulent transactions, noting that trading in thinly traded stock options was not inherently unusual, especially given stock exchange incentive schemes. The tribunal determined the assessee's trades were genuine during the specified period. Consequently, the tribunal deleted the disallowed loss and allowed the assessee's appeal, emphasizing the need for concrete evidence before challenging legitimate trading activities.
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