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 analyzed cash deposit during demonetization, finding no unexplained income. Assessee declared total sales of Rs. 49,03,470/- including cash sales of Rs. 30,25,930/-, with VAT returns matching ITR declarations. Independent VAT authorities confirmed no errors. Cash deposited originated from legitimate sales proceeds existing prior to demonetization announcement. Following precedent in similar cases, ITAT deleted addition under Section 69A, rejecting tax authorities' conjecture of undisclosed income. Tribunal ruled in favor of assessee, holding that taxing same income twice would be improper and unsupported by evidence.
ITAT analyzed cash deposit during demonetization, finding no unexplained income. Assessee declared total sales of Rs. 49,03,470/- including cash sales of Rs. 30,25,930/-, with VAT returns matching ITR declarations. Independent VAT authorities confirmed no errors. Cash deposited originated from legitimate sales proceeds existing prior to demonetization announcement. Following precedent in similar cases, ITAT deleted addition under Section 69A, rejecting tax authorities' conjecture of undisclosed income. Tribunal ruled in favor of assessee, holding that taxing same income twice would be improper and unsupported by evidence.
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