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 assessee's appeal regarding unexplained cash deposits under Section 69A, finding inadequate inquiry by tax authorities. Assessee, who was minor at time of alleged deposits, contended bank account was opened through PAN misuse without his knowledge and filed police complaint. Despite assessee's submissions regarding lack of financial capacity and fraudulent account opening, AO failed to obtain crucial bank documents including account opening forms, statements, or conduct proper verification with bank officials. CIT(A) erroneously confirmed addition solely based on absence of police inquiry. ITAT held that lack of police investigation cannot justify confirming substantial unexplained deposits when assessee provided specific defense and authorities conducted no meaningful verification. Matter remanded to AO for fresh assessment with proper inquiry into account opening, operation, and deposit sources.
ITAT allowed assessee's appeal regarding unexplained cash deposits under Section 69A, finding inadequate inquiry by tax authorities. Assessee, who was minor at time of alleged deposits, contended bank account was opened through PAN misuse without his knowledge and filed police complaint. Despite assessee's submissions regarding lack of financial capacity and fraudulent account opening, AO failed to obtain crucial bank documents including account opening forms, statements, or conduct proper verification with bank officials. CIT(A) erroneously confirmed addition solely based on absence of police inquiry. ITAT held that lack of police investigation cannot justify confirming substantial unexplained deposits when assessee provided specific defense and authorities conducted no meaningful verification. Matter remanded to AO for fresh assessment with proper inquiry into account opening, operation, and deposit sources.
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