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 adjudicated a tax dispute regarding cash loan documentation. The tribunal determined that the contested document did not constitute a Hundi, as it represented a bilateral transaction and was not executed on traditional Hundi paper. Consequently, the statutory presumption under Section 69D was deemed inapplicable. Relying on precedential judicial interpretation, the tribunal rejected revenue's contention and found the disallowance under Section 69D unsustainable. The appellate tribunal ultimately allowed the assessee's appeal, nullifying the challenged tax assessment based on procedural and documentary insufficiencies in characterizing the financial instrument as a Hundi.
ITAT adjudicated a tax dispute regarding cash loan documentation. The tribunal determined that the contested document did not constitute a Hundi, as it represented a bilateral transaction and was not executed on traditional Hundi paper. Consequently, the statutory presumption under Section 69D was deemed inapplicable. Relying on precedential judicial interpretation, the tribunal rejected revenue's contention and found the disallowance under Section 69D unsustainable. The appellate tribunal ultimately allowed the assessee's appeal, nullifying the challenged tax assessment based on procedural and documentary insufficiencies in characterizing the financial instrument as a Hundi.
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