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 deleted the addition under section 69A based on seized loose papers, finding the AO's reliance on uncorroborated scribblings insufficient to establish unexplained income. The tribunal noted the AO's failure to verify transactions with named individuals, one of whom denied involvement, rendering the addition founded on mere suspicion. Consequently, the addition and related interest were set aside. However, the tribunal upheld the disallowance of expenses and addition for unexplained cash, as the assessee did not contest the CIT(A)'s prior confirmation of these disallowances. Thus, the appeal succeeded only in deleting the addition under section 69A, while the other grounds were dismissed for lack of challenge.
The ITAT deleted the addition under section 69A based on seized loose papers, finding the AO's reliance on uncorroborated scribblings insufficient to establish unexplained income. The tribunal noted the AO's failure to verify transactions with named individuals, one of whom denied involvement, rendering the addition founded on mere suspicion. Consequently, the addition and related interest were set aside. However, the tribunal upheld the disallowance of expenses and addition for unexplained cash, as the assessee did not contest the CIT(A)'s prior confirmation of these disallowances. Thus, the appeal succeeded only in deleting the addition under section 69A, while the other grounds were dismissed for lack of challenge.
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