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 several key rulings against the Revenue's appeals. The Tribunal dismissed multiple grounds raised by the tax department, including challenges to discount calculations, alleged bogus purchases, unexplained loans, and undisclosed cash receipts. Notably, the ITAT found insufficient evidence to substantiate the Assessing Officer's allegations of on-money receipts and deemed dividends. The Tribunal consistently emphasized the need for concrete proof and rejected ad hoc additions. Most significantly, the ITAT supported the CIT(A)'s findings, finding no material to disturb previous deletions of tax additions. The Revenue's appeals were systematically dismissed across various grounds, reinforcing procedural fairness and evidentiary standards in tax assessment.
ITAT upheld several key rulings against the Revenue's appeals. The Tribunal dismissed multiple grounds raised by the tax department, including challenges to discount calculations, alleged bogus purchases, unexplained loans, and undisclosed cash receipts. Notably, the ITAT found insufficient evidence to substantiate the Assessing Officer's allegations of on-money receipts and deemed dividends. The Tribunal consistently emphasized the need for concrete proof and rejected ad hoc additions. Most significantly, the ITAT supported the CIT(A)'s findings, finding no material to disturb previous deletions of tax additions. The Revenue's appeals were systematically dismissed across various grounds, reinforcing procedural fairness and evidentiary standards in tax assessment.
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