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...
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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 allowed the assessee's appeal, deleting additions made under sections 69 and 56 for alleged cash loan and notional interest. The tribunal found no incriminating material in the assessee's possession during search proceedings. The additions were deemed beyond jurisdictional scope under section 153A, as no substantive evidence supported claims of loan advancement or unexplained assets. The tribunal noted the loan allegations were based on presumptions involving third parties, and the jewellery additions were reasonable given the family's size. Following precedential guidelines, the tribunal comprehensively rejected revenue's contentions and provided full relief to the assessee.
ITAT allowed the assessee's appeal, deleting additions made under sections 69 and 56 for alleged cash loan and notional interest. The tribunal found no incriminating material in the assessee's possession during search proceedings. The additions were deemed beyond jurisdictional scope under section 153A, as no substantive evidence supported claims of loan advancement or unexplained assets. The tribunal noted the loan allegations were based on presumptions involving third parties, and the jewellery additions were reasonable given the family's size. Following precedential guidelines, the tribunal comprehensively rejected revenue's contentions and provided full relief to the assessee.
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