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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT allowed assessee's appeal and confirmed CIT(A)'s deletion of addition under Section 68. The assessee successfully discharged the primary onus by providing confirmation letters, bank statements, income tax returns, and statements establishing lender's identity, creditworthiness, and transaction genuineness. Despite AO's disbelief of unsecured loans without interest charges, the tribunal noted AO did not question partial loan repayments with appropriate TDS in current and subsequent assessment years. The tribunal held that assessee provided sufficient prima facie evidence including lender's PAN, address, contra confirmations, and financial documents. Addition under Section 68 was deemed unsustainable in law as all three conditions - identity, genuineness, and creditworthiness - were adequately established through documentary evidence submitted.
ITAT allowed assessee's appeal and confirmed CIT(A)'s deletion of addition under Section 68. The assessee successfully discharged the primary onus by providing confirmation letters, bank statements, income tax returns, and statements establishing lender's identity, creditworthiness, and transaction genuineness. Despite AO's disbelief of unsecured loans without interest charges, the tribunal noted AO did not question partial loan repayments with appropriate TDS in current and subsequent assessment years. The tribunal held that assessee provided sufficient prima facie evidence including lender's PAN, address, contra confirmations, and financial documents. Addition under Section 68 was deemed unsustainable in law as all three conditions - identity, genuineness, and creditworthiness - were adequately established through documentary evidence submitted.
Note: It is a system-generated summary and is for quick reference only.