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 against additions under section 68 for unexplained cash deposits during demonetization period. The assessing officer had accepted the assessee's entire sales and purchases as genuine but made additions claiming artificial scenarios where unaccounted income was shown as cash sales then deposited. ITAT found no evidence supporting the officer's observations. The assessee provided comprehensive documentation including day-wise cash books with customer names, party-wise purchase and sales registers with PAN details, and bank statements. The cash deposits were properly recorded as sales in profit and loss accounts and offered for taxation. ITAT relied on precedents establishing that where cash deposits from trading activities are supported by relevant evidence and accepted by tax authorities, such deposits cannot be treated as undisclosed income under sections 69A and 115BBE.
ITAT allowed the appeal against additions under section 68 for unexplained cash deposits during demonetization period. The assessing officer had accepted the assessee's entire sales and purchases as genuine but made additions claiming artificial scenarios where unaccounted income was shown as cash sales then deposited. ITAT found no evidence supporting the officer's observations. The assessee provided comprehensive documentation including day-wise cash books with customer names, party-wise purchase and sales registers with PAN details, and bank statements. The cash deposits were properly recorded as sales in profit and loss accounts and offered for taxation. ITAT relied on precedents establishing that where cash deposits from trading activities are supported by relevant evidence and accepted by tax authorities, such deposits cannot be treated as undisclosed income under sections 69A and 115BBE.
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