TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
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Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
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Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT upheld the assessment order under section 153C, rejecting the assessee's challenge to the satisfaction note. The tribunal found the satisfaction note valid, as it correctly recorded the seized documents' relevance to the assessment year. The tribunal also confirmed the addition of unexplained cash receipt under section 69A, dismissing the assessee's contentions about the seized documents being inadmissible. The tribunal held that the seized document showing a cash receipt of Rs. 1,30,50,000 was genuine and taxable, despite the assessee's claims of deal cancellation and lack of corroborative evidence. Consequently, the appeal was dismissed, maintaining the original assessment order and additional tax liability.
ITAT upheld the assessment order under section 153C, rejecting the assessee's challenge to the satisfaction note. The tribunal found the satisfaction note valid, as it correctly recorded the seized documents' relevance to the assessment year. The tribunal also confirmed the addition of unexplained cash receipt under section 69A, dismissing the assessee's contentions about the seized documents being inadmissible. The tribunal held that the seized document showing a cash receipt of Rs. 1,30,50,000 was genuine and taxable, despite the assessee's claims of deal cancellation and lack of corroborative evidence. Consequently, the appeal was dismissed, maintaining the original assessment order and additional tax liability.
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