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 appeal and deleted the entire addition made by AO under section 115BBE for unexplained cash deposits during demonetization period. The assessee successfully explained the source of cash deposits totaling Rs. 43,49,428/- by demonstrating that cash balance was maintained in regular books of account accepted by AO, and deposits originated from legitimate cash withdrawals from bank accounts and available cash in hand. CIT(A) had erred by providing only 50% relief without detailed factual analysis. ITAT found the source of cash deposits adequately explained through regular banking transactions and book entries, concluding no addition was warranted as the deposits were from explained sources rather than unexplained cash.
ITAT allowed the appeal and deleted the entire addition made by AO under section 115BBE for unexplained cash deposits during demonetization period. The assessee successfully explained the source of cash deposits totaling Rs. 43,49,428/- by demonstrating that cash balance was maintained in regular books of account accepted by AO, and deposits originated from legitimate cash withdrawals from bank accounts and available cash in hand. CIT(A) had erred by providing only 50% relief without detailed factual analysis. ITAT found the source of cash deposits adequately explained through regular banking transactions and book entries, concluding no addition was warranted as the deposits were from explained sources rather than unexplained cash.
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