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 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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