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 allowed the assessee's appeal and remanded the matter to CIT(A) for fresh adjudication. The tribunal found insufficient evidence to conclusively determine the source of cash deposits, noting a 15-20 day gap between cash withdrawals and redeposits. While the AO alleged unexplained cash deposits under Section 69A, the tribunal observed that the burden of proof was on the AO to establish undisclosed sources, which was not adequately discharged. The case was restored to CIT(A) to thoroughly examine the assessee's cash flow statement and factual claims, ensuring principles of natural justice are followed in reassessing the unexplained cash deposits.
ITAT allowed the assessee's appeal and remanded the matter to CIT(A) for fresh adjudication. The tribunal found insufficient evidence to conclusively determine the source of cash deposits, noting a 15-20 day gap between cash withdrawals and redeposits. While the AO alleged unexplained cash deposits under Section 69A, the tribunal observed that the burden of proof was on the AO to establish undisclosed sources, which was not adequately discharged. The case was restored to CIT(A) to thoroughly examine the assessee's cash flow statement and factual claims, ensuring principles of natural justice are followed in reassessing the unexplained cash deposits.
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