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 challenging addition under Section 68 read with Section 115BBE for unexplained credits. Upon conversion from private company to LLP, assessee transferred share capital, reserves and surplus to partners' accounts. AO alleged violation of Section 47(xiiib)(f) conditions prohibiting distribution of accumulated profits within three years of conversion, making addition under Section 68. CIT(A) deleted the addition. ITAT held Section 47 pertains only to capital gains computation under Section 45, not unexplained credits under Section 68. The transferred amounts had identifiable nature and source, being company's own accumulated profits. Addition was erroneously made in assessee's hands when credits appeared in partners' accounts. None of Section 68's ingredients were satisfied as credits were not unexplained. CIT(A)'s deletion of addition was upheld.
ITAT allowed assessee's appeal challenging addition under Section 68 read with Section 115BBE for unexplained credits. Upon conversion from private company to LLP, assessee transferred share capital, reserves and surplus to partners' accounts. AO alleged violation of Section 47(xiiib)(f) conditions prohibiting distribution of accumulated profits within three years of conversion, making addition under Section 68. CIT(A) deleted the addition. ITAT held Section 47 pertains only to capital gains computation under Section 45, not unexplained credits under Section 68. The transferred amounts had identifiable nature and source, being company's own accumulated profits. Addition was erroneously made in assessee's hands when credits appeared in partners' accounts. None of Section 68's ingredients were satisfied as credits were not unexplained. CIT(A)'s deletion of addition was upheld.
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