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 for statistical purposes regarding addition under section 69A for unexplained cash deposits allegedly from vegetable and milk sales. Tribunal found assessee failed to provide documentary evidence of milk and vegetable supplies across India, transportation proof, or satisfactory explanation for frequent cash withdrawals following deposits. However, ITAT accepted assessee's legal contention that cash deposits cannot be treated as undisclosed income without crediting prior withdrawals from the same bank account, unless revenue demonstrates alternative utilization of withdrawn cash. Matter remanded to Assessing Officer for verification and determination per established legal principles requiring credit for withdrawals when assessing unexplained deposits in identical bank accounts.
ITAT allowed assessee's appeal for statistical purposes regarding addition under section 69A for unexplained cash deposits allegedly from vegetable and milk sales. Tribunal found assessee failed to provide documentary evidence of milk and vegetable supplies across India, transportation proof, or satisfactory explanation for frequent cash withdrawals following deposits. However, ITAT accepted assessee's legal contention that cash deposits cannot be treated as undisclosed income without crediting prior withdrawals from the same bank account, unless revenue demonstrates alternative utilization of withdrawn cash. Matter remanded to Assessing Officer for verification and determination per established legal principles requiring credit for withdrawals when assessing unexplained deposits in identical bank accounts.
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