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 partial addition of Rs. 2,25,000 as unexplained creditor under Section 68, while dismissing Revenue's challenge to remaining loan transactions. The tribunal found the assessee successfully established three key ingredients: identity, creditworthiness, and genuineness of transactions from the lender. Despite absence of ITR, the tribunal accepted the loan's source and routing, relying on documentary evidence including account confirmations and bank records. Consistent with precedential rulings, the tribunal concluded no unaccounted income was demonstrated, thereby partially allowing the assessee's appeal and confirming only a limited portion of the disputed amount.
ITAT upheld partial addition of Rs. 2,25,000 as unexplained creditor under Section 68, while dismissing Revenue's challenge to remaining loan transactions. The tribunal found the assessee successfully established three key ingredients: identity, creditworthiness, and genuineness of transactions from the lender. Despite absence of ITR, the tribunal accepted the loan's source and routing, relying on documentary evidence including account confirmations and bank records. Consistent with precedential rulings, the tribunal concluded no unaccounted income was demonstrated, thereby partially allowing the assessee's appeal and confirming only a limited portion of the disputed amount.
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