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 ruled on multiple grounds related to assessment reopening and income determination based on seized diaries. The Tribunal upheld the assessment order with key modifications: (1) land trading profit to be computed at 13.14% instead of 15%, (2) share trading profit to be calculated at 8%, (3) Maalkhaate trading income to be estimated at 10%, and (4) allowing telescoping of income already taxed in preceding years with peak additions. The Tribunal rejected the assessee's objections regarding jurisdiction, reopening validity, and seized document interpretation while directing the Assessing Officer to recompute certain income components based on specific guidelines provided in the order.
ITAT ruled on multiple grounds related to assessment reopening and income determination based on seized diaries. The Tribunal upheld the assessment order with key modifications: (1) land trading profit to be computed at 13.14% instead of 15%, (2) share trading profit to be calculated at 8%, (3) Maalkhaate trading income to be estimated at 10%, and (4) allowing telescoping of income already taxed in preceding years with peak additions. The Tribunal rejected the assessee's objections regarding jurisdiction, reopening validity, and seized document interpretation while directing the Assessing Officer to recompute certain income components based on specific guidelines provided in the order.
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