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 set aside CIT(A) order regarding cash deposits totaling Rs. 41,07,000 treated as unexplained under section 68. Assessee claimed deposits represented gifts from blood relations and agricultural income receipts but failed to provide strong arguments before lower authorities. However, ITAT accepted assessee's contention that addition should be restricted to peak credit of Rs. 15,27,000 rather than entire deposit amount. Matter remanded to AO for de-novo adjudication with directions to verify peak credit calculations and restrict addition accordingly after granting reasonable opportunity of hearing. AO instructed to examine supporting documentation and chart submitted by assessee demonstrating peak credit working. Appeal partly allowed for statistical purposes.
ITAT set aside CIT(A) order regarding cash deposits totaling Rs. 41,07,000 treated as unexplained under section 68. Assessee claimed deposits represented gifts from blood relations and agricultural income receipts but failed to provide strong arguments before lower authorities. However, ITAT accepted assessee's contention that addition should be restricted to peak credit of Rs. 15,27,000 rather than entire deposit amount. Matter remanded to AO for de-novo adjudication with directions to verify peak credit calculations and restrict addition accordingly after granting reasonable opportunity of hearing. AO instructed to examine supporting documentation and chart submitted by assessee demonstrating peak credit working. Appeal partly allowed for statistical purposes.
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