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 assessee's appeal regarding bogus purchase additions. The assessee joined M/s. Gauri Construction as partner in AY 2011-12 when it converted from proprietorship to firm. Commercial tax authorities subsequently identified bogus transactions of M/s. Gauri Construction for AY 2010-11, which were incorrectly tagged to the assessee's PAN despite occurring before partnership formation. CIT(A) correctly determined that since all evidence related to M/s. Gauri Construction's transactions, the AO lacked justification for making adverse inferences against the assessee personally. ITAT upheld CIT(A)'s decision to delete the addition, finding no basis for attributing pre-partnership transactions to the individual assessee.
ITAT allowed the assessee's appeal regarding bogus purchase additions. The assessee joined M/s. Gauri Construction as partner in AY 2011-12 when it converted from proprietorship to firm. Commercial tax authorities subsequently identified bogus transactions of M/s. Gauri Construction for AY 2010-11, which were incorrectly tagged to the assessee's PAN despite occurring before partnership formation. CIT(A) correctly determined that since all evidence related to M/s. Gauri Construction's transactions, the AO lacked justification for making adverse inferences against the assessee personally. ITAT upheld CIT(A)'s decision to delete the addition, finding no basis for attributing pre-partnership transactions to the individual assessee.
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