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 principle of consistency, affirming that the assessee's income declared under presumptive taxation u/s 44AD must be accepted as in prior years. The assessee, engaged in wholesale livestock trading and mutton sales, provided valid certification and evidence confirming the business's legitimacy. Previous assessments under section 153A r.w.s. 143(3) consistently accepted the returns filed on a presumptive basis without material change in facts. The Tribunal held that proof of an eligible business existed, and absence of detailed invoices was excused due to the nature of the livestock trade in J&K. The seized cash of Rs. 7 lakhs was satisfactorily explained as part of the assessee's normal business cash flow. Consequently, the addition u/s 69A was disallowed, and the appeal was allowed in favor of the assessee.
The ITAT upheld the principle of consistency, affirming that the assessee's income declared under presumptive taxation u/s 44AD must be accepted as in prior years. The assessee, engaged in wholesale livestock trading and mutton sales, provided valid certification and evidence confirming the business's legitimacy. Previous assessments under section 153A r.w.s. 143(3) consistently accepted the returns filed on a presumptive basis without material change in facts. The Tribunal held that proof of an eligible business existed, and absence of detailed invoices was excused due to the nature of the livestock trade in J&K. The seized cash of Rs. 7 lakhs was satisfactorily explained as part of the assessee's normal business cash flow. Consequently, the addition u/s 69A was disallowed, and the appeal was allowed in favor of the assessee.
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