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 held that the reopening of assessment based on alleged unexplained cash deposits exceeding Rs. 1 lakh was unjustified due to factual inaccuracies and lack of application of mind by the AO. The AO's reasons were founded on incorrect figures and failed to establish a nexus between the assessee's declared turnover and the purported information. The assessee provided detailed records substantiating the deposits as legitimate sale proceeds, corroborated by bank statements and inventory data, which the AO disregarded without proper analysis. Consequently, the ITAT upheld the CIT(A)'s decision to quash the reassessment, finding no merit in the Revenue's appeal. The unexplained cash credit allegation was dismissed for lack of evidentiary support and improper evaluation by the AO.
The ITAT held that the reopening of assessment based on alleged unexplained cash deposits exceeding Rs. 1 lakh was unjustified due to factual inaccuracies and lack of application of mind by the AO. The AO's reasons were founded on incorrect figures and failed to establish a nexus between the assessee's declared turnover and the purported information. The assessee provided detailed records substantiating the deposits as legitimate sale proceeds, corroborated by bank statements and inventory data, which the AO disregarded without proper analysis. Consequently, the ITAT upheld the CIT(A)'s decision to quash the reassessment, finding no merit in the Revenue's appeal. The unexplained cash credit allegation was dismissed for lack of evidentiary support and improper evaluation by the AO.
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