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 rejected assessee's books of accounts due to suppressed purchases, sales, and unaccounted payments. The tribunal directed application of 5% net profit rate on aggregate turnover comprising both recorded sales and unrecorded sales discovered in impounded documents SP-68, SP-73, and SP-42. The Assessing Officer was instructed to calculate difference between estimated profit and declared profit, adding such difference to returned income. No separate additions were permitted for other expenditure heads, low household expenses, or undisclosed investments in daughters' names, as these were deemed covered by enhanced income estimation. The appeal was decided partly in favor of the assessee with consequential relief granted.
ITAT rejected assessee's books of accounts due to suppressed purchases, sales, and unaccounted payments. The tribunal directed application of 5% net profit rate on aggregate turnover comprising both recorded sales and unrecorded sales discovered in impounded documents SP-68, SP-73, and SP-42. The Assessing Officer was instructed to calculate difference between estimated profit and declared profit, adding such difference to returned income. No separate additions were permitted for other expenditure heads, low household expenses, or undisclosed investments in daughters' names, as these were deemed covered by enhanced income estimation. The appeal was decided partly in favor of the assessee with consequential relief granted.
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