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 addition of unexplained share application money under Section 68, rejecting assessee's discharge of onus regarding investor identity, creditworthiness, and transaction genuineness. Tribunal found entire share application money received in cash without proper transaction dates filed before authorities constituted self-serving evidence. Director's non-appearance for examination despite partial statement recording, combined with ongoing company irregularity proceedings, established transactions as make-believe scheme lacking genuineness. ITAT distinguished criminal proceedings requiring proof beyond reasonable doubt from assessment proceedings governed by preponderance of probabilities, human probabilities test, and surrounding circumstances standard. Despite pending SIT verdict potentially providing criminal relief, Tribunal confirmed CIT(A)'s order applying lower civil standard of proof appropriate for income tax assessments, dismissing assessee's grounds and sustaining Section 68 addition.
ITAT upheld addition of unexplained share application money under Section 68, rejecting assessee's discharge of onus regarding investor identity, creditworthiness, and transaction genuineness. Tribunal found entire share application money received in cash without proper transaction dates filed before authorities constituted self-serving evidence. Director's non-appearance for examination despite partial statement recording, combined with ongoing company irregularity proceedings, established transactions as make-believe scheme lacking genuineness. ITAT distinguished criminal proceedings requiring proof beyond reasonable doubt from assessment proceedings governed by preponderance of probabilities, human probabilities test, and surrounding circumstances standard. Despite pending SIT verdict potentially providing criminal relief, Tribunal confirmed CIT(A)'s order applying lower civil standard of proof appropriate for income tax assessments, dismissing assessee's grounds and sustaining Section 68 addition.
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