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 held that the assessee failed to produce the approval order under Section 153D, rendering challenge to the assessment order ineffective. The tribunal rejected additional grounds raised by the assessee due to lack of substantive evidence. The AO's assessment was found problematic regarding income declaration, with insufficient documentation to explain cash sources during search proceedings. The assessee's failure to provide supporting evidence for income from real estate business and cash explanations led to dismissal of the appeal, upholding the original assessment order as prejudicial to revenue interests.
ITAT held that the assessee failed to produce the approval order under Section 153D, rendering challenge to the assessment order ineffective. The tribunal rejected additional grounds raised by the assessee due to lack of substantive evidence. The AO's assessment was found problematic regarding income declaration, with insufficient documentation to explain cash sources during search proceedings. The assessee's failure to provide supporting evidence for income from real estate business and cash explanations led to dismissal of the appeal, upholding the original assessment order as prejudicial to revenue interests.
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