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 addressed multiple taxation issues involving unexplained income and profit calculations. The tribunal found that when entire contract receipts were treated as unexplained, no further profit addition was justified. The CIT(A)'s order was set aside due to procedural irregularities in admitting additional evidence without providing the AO an opportunity to examine such evidence, as mandated under Rule 46A(3) of IT Rules. The tribunal upheld the 10% profit rate calculation, noting it was more reasonable than the AO's unsubstantiated 20% rate. The matter was remanded to the first appellate authority for reconsideration, ensuring procedural compliance and fair assessment of the taxpayer's income.
ITAT addressed multiple taxation issues involving unexplained income and profit calculations. The tribunal found that when entire contract receipts were treated as unexplained, no further profit addition was justified. The CIT(A)'s order was set aside due to procedural irregularities in admitting additional evidence without providing the AO an opportunity to examine such evidence, as mandated under Rule 46A(3) of IT Rules. The tribunal upheld the 10% profit rate calculation, noting it was more reasonable than the AO's unsubstantiated 20% rate. The matter was remanded to the first appellate authority for reconsideration, ensuring procedural compliance and fair assessment of the taxpayer's income.
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