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 appeal and deleted the addition made under section 69A regarding cash deposits in Specified Bank Notes during demonetization period. The assessee, proprietor of petroleum products business, deposited cash from 24.11.2016 to 30.12.2016. ITAT held that despite regulatory ambiguity during demonetization transition period until 31.12.2016, the source explanation for cash deposits cannot be rejected merely because assessee accepted SBNs in technical violation of government notifications, particularly when the AO did not dispute that assessee made unaccounted cash deposits. Following precedent in Tamil Nadu State Marketing Corporation Ltd., ITAT concluded that addition under section 69A was unjustified and set aside CIT(A)'s order confirming the assessment.
ITAT allowed the appeal and deleted the addition made under section 69A regarding cash deposits in Specified Bank Notes during demonetization period. The assessee, proprietor of petroleum products business, deposited cash from 24.11.2016 to 30.12.2016. ITAT held that despite regulatory ambiguity during demonetization transition period until 31.12.2016, the source explanation for cash deposits cannot be rejected merely because assessee accepted SBNs in technical violation of government notifications, particularly when the AO did not dispute that assessee made unaccounted cash deposits. Following precedent in Tamil Nadu State Marketing Corporation Ltd., ITAT concluded that addition under section 69A was unjustified and set aside CIT(A)'s order confirming the assessment.
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