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 upheld the Assessment Officer's (AO) order regarding unexplained cash deposits in the assessee's bank account. The tribunal found no credible evidence supporting the assessee's claim that the deposits represented sale proceeds from her father's property. The assessee failed to provide documentary proof or explain the source of 18 cash deposits made between 04/05/2010 and 08/13/2010. The reopening of assessment under Section 147 was deemed valid, as the AO had proper reason to believe income had escaped assessment. The tribunal emphasized that at the reassessment stage, the existence of material is crucial, not its adequacy. Consequently, the assessee's appeal was dismissed, confirming the original tax demand.
ITAT upheld the Assessment Officer's (AO) order regarding unexplained cash deposits in the assessee's bank account. The tribunal found no credible evidence supporting the assessee's claim that the deposits represented sale proceeds from her father's property. The assessee failed to provide documentary proof or explain the source of 18 cash deposits made between 04/05/2010 and 08/13/2010. The reopening of assessment under Section 147 was deemed valid, as the AO had proper reason to believe income had escaped assessment. The tribunal emphasized that at the reassessment stage, the existence of material is crucial, not its adequacy. Consequently, the assessee's appeal was dismissed, confirming the original tax demand.
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