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 dismissed Revenue's appeals, upholding CIT(A)'s deletion of addition under Section 69. The Assessing Officer's order was found defective due to lack of substantive evidence, failure to confront key witness statements, and inability to establish direct nexus between seized documents and assessee's transactions. The tribunal noted that neither purchase nor seller parties admitted connection to seized documents, and the assessee demonstrated regular transaction records from ledger accounts. Procedural irregularities in assessment, including non-compliance with Section 145(3) and rejection of books of accounts without proper justification, led to the appellate order's confirmation.
ITAT dismissed Revenue's appeals, upholding CIT(A)'s deletion of addition under Section 69. The Assessing Officer's order was found defective due to lack of substantive evidence, failure to confront key witness statements, and inability to establish direct nexus between seized documents and assessee's transactions. The tribunal noted that neither purchase nor seller parties admitted connection to seized documents, and the assessee demonstrated regular transaction records from ledger accounts. Procedural irregularities in assessment, including non-compliance with Section 145(3) and rejection of books of accounts without proper justification, led to the appellate order's confirmation.
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