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 additions made under Section 68 read with Section 115BBE regarding proceeds from cash sales of metal scrap. The Tribunal held that when sales amounts are already included in audited books of accounts and accepted by Revenue, no further additions can be made without rejecting the books. The assessee provided substantiating documents for cash sales with no defects pointed out by Assessing Officer. Same sales figures were accepted under VAT/GST assessment, precluding differential treatment. Addition was based on surmises without adverse material or independent inquiry. Following precedent in Hirapanna Jewellers case, the Tribunal concluded that additions require rejection of books of accounts, which did not occur here, making the addition unjustified and warranting deletion.
ITAT allowed the appeal and deleted additions made under Section 68 read with Section 115BBE regarding proceeds from cash sales of metal scrap. The Tribunal held that when sales amounts are already included in audited books of accounts and accepted by Revenue, no further additions can be made without rejecting the books. The assessee provided substantiating documents for cash sales with no defects pointed out by Assessing Officer. Same sales figures were accepted under VAT/GST assessment, precluding differential treatment. Addition was based on surmises without adverse material or independent inquiry. Following precedent in Hirapanna Jewellers case, the Tribunal concluded that additions require rejection of books of accounts, which did not occur here, making the addition unjustified and warranting deletion.
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