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 addition of Rs. 1.60 crores as business income surrendered during the survey, confirming suppression of scrap sale proceeds linked to the assessee's manufacturing activity. The Tribunal affirmed the CIT(A)'s deletion of additions totaling Rs. 34,51,288 arising from seized documents and unsecured loans, as the assessee satisfactorily demonstrated the genuineness and source of these transactions with supporting evidence. However, the extrapolation of unexplained wages and salary payments beyond the survey date was disallowed; the Tribunal restricted additions to the period up to 08.10.2018, consistent with documentary proof and judicial precedents. Consequently, the addition of Rs. 1,02,10,256/- on this account was deleted. The appeal was partly allowed, sustaining the survey-related income addition but deleting other contested additions.
The ITAT upheld the addition of Rs. 1.60 crores as business income surrendered during the survey, confirming suppression of scrap sale proceeds linked to the assessee's manufacturing activity. The Tribunal affirmed the CIT(A)'s deletion of additions totaling Rs. 34,51,288 arising from seized documents and unsecured loans, as the assessee satisfactorily demonstrated the genuineness and source of these transactions with supporting evidence. However, the extrapolation of unexplained wages and salary payments beyond the survey date was disallowed; the Tribunal restricted additions to the period up to 08.10.2018, consistent with documentary proof and judicial precedents. Consequently, the addition of Rs. 1,02,10,256/- on this account was deleted. The appeal was partly allowed, sustaining the survey-related income addition but deleting other contested additions.
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