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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HC held that additions under Section 69A were valid based on seized diary notings. The entries in the diaries contained recordings of flat booking receipts, which were corroborated by reconciliation with formal accounting records. The court emphasized that diaries can qualify as books of accounts if they contain accounting information, particularly given the expansive definition under Section 2(12A). The fundamental premise that additions were made solely on standalone documents was rejected. The court noted that cash entries not reflected in software-based accounts could still be legitimate basis for tax assessment. Diary entries were not considered random documents but substantive evidence of financial transactions. No substantial legal question was found to merit further review.
HC held that additions under Section 69A were valid based on seized diary notings. The entries in the diaries contained recordings of flat booking receipts, which were corroborated by reconciliation with formal accounting records. The court emphasized that diaries can qualify as books of accounts if they contain accounting information, particularly given the expansive definition under Section 2(12A). The fundamental premise that additions were made solely on standalone documents was rejected. The court noted that cash entries not reflected in software-based accounts could still be legitimate basis for tax assessment. Diary entries were not considered random documents but substantive evidence of financial transactions. No substantial legal question was found to merit further review.
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