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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The ITAT upheld the CIT(A)'s order quashing additions made by the AO treating 35% of cash deposits as unexplained cash credits and disallowances on debtors outstanding without concrete evidence or issuance of show cause notices, thereby violating natural justice. The AO's reliance on presumptions without specific findings or supporting evidence, including failure to justify the proportion of cash treated as unexplained credit, was found unsustainable. The assessee's sales figures were consistent with prior years, negating the AO's basis for additions. Consequently, the Tribunal dismissed the Revenue's appeal and affirmed deletion of the disputed additions, emphasizing adherence to evidentiary standards and procedural fairness in assessments.
The ITAT upheld the CIT(A)'s order quashing additions made by the AO treating 35% of cash deposits as unexplained cash credits and disallowances on debtors outstanding without concrete evidence or issuance of show cause notices, thereby violating natural justice. The AO's reliance on presumptions without specific findings or supporting evidence, including failure to justify the proportion of cash treated as unexplained credit, was found unsustainable. The assessee's sales figures were consistent with prior years, negating the AO's basis for additions. Consequently, the Tribunal dismissed the Revenue's appeal and affirmed deletion of the disputed additions, emphasizing adherence to evidentiary standards and procedural fairness in assessments.
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