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 concerning gross profit estimation after rejection of books of accounts for a livestock dealer. The assessee purchased animals from farmers and sold to slaughterhouses, conducting transactions primarily in cash without formal bills or vouchers due to the nature of the business. The coordinate bench in Salauddin Saifi established 0.5% as reasonable profit for this trade. The CIT(A) had enhanced the GP ratio based on comparable cases, but ITAT directed the AO to restrict GP to 0.5%. Since the assessee had already declared 0.6% GP, which exceeded the benchmark, ITAT directed retention of the declared rate, allowing the assessee's grounds and providing favorable relief.
ITAT allowed the appeal concerning gross profit estimation after rejection of books of accounts for a livestock dealer. The assessee purchased animals from farmers and sold to slaughterhouses, conducting transactions primarily in cash without formal bills or vouchers due to the nature of the business. The coordinate bench in Salauddin Saifi established 0.5% as reasonable profit for this trade. The CIT(A) had enhanced the GP ratio based on comparable cases, but ITAT directed the AO to restrict GP to 0.5%. Since the assessee had already declared 0.6% GP, which exceeded the benchmark, ITAT directed retention of the declared rate, allowing the assessee's grounds and providing favorable relief.
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