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...
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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 a tax dispute involving two primary issues. The tribunal rejected Revenue's claims regarding an alleged accommodation entry transaction, finding insufficient evidence to substantiate the allegation of bogus unsecured loans. The tribunal upheld the CIT(A)'s deletion of additions under section 68 and section 69C, determining that the INR 4 crore received was from a legitimate sale transaction of convertible debentures. Additionally, the tribunal prevented double disallowance under section 14A by recognizing the assessee's suo motu disallowance, thereby preventing impermissible addition of non-existent expenditure. Consequently, all grounds raised in Revenue's appeal were dismissed.
ITAT adjudicated a tax dispute involving two primary issues. The tribunal rejected Revenue's claims regarding an alleged accommodation entry transaction, finding insufficient evidence to substantiate the allegation of bogus unsecured loans. The tribunal upheld the CIT(A)'s deletion of additions under section 68 and section 69C, determining that the INR 4 crore received was from a legitimate sale transaction of convertible debentures. Additionally, the tribunal prevented double disallowance under section 14A by recognizing the assessee's suo motu disallowance, thereby preventing impermissible addition of non-existent expenditure. Consequently, all grounds raised in Revenue's appeal were dismissed.
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