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 validity of the Assessment Order issued with a Document Identification Number (DIN) under Section 292B, dismissing the Assessee's technical objections. The Tribunal rejected the challenge to jurisdiction under Section 153D based on the timing of approval, finding no infirmity absent contrary evidence. Regarding additions under Section 69A for undisclosed foreign assets, the ITAT accepted the Assessee's evidence demonstrating that the bank account and portfolio belonged to a trust, not the Assessee individually, and that the source of funds was satisfactorily explained. Consequently, the additions were deleted. The Tribunal further held that jurisdiction under Section 153A was improperly assumed in the absence of incriminating material for the relevant year, rendering the assessment under Section 153A invalid. The appeal was allowed to the extent of deleting the additions and quashing the Section 153A assessment.
The ITAT upheld the validity of the Assessment Order issued with a Document Identification Number (DIN) under Section 292B, dismissing the Assessee's technical objections. The Tribunal rejected the challenge to jurisdiction under Section 153D based on the timing of approval, finding no infirmity absent contrary evidence. Regarding additions under Section 69A for undisclosed foreign assets, the ITAT accepted the Assessee's evidence demonstrating that the bank account and portfolio belonged to a trust, not the Assessee individually, and that the source of funds was satisfactorily explained. Consequently, the additions were deleted. The Tribunal further held that jurisdiction under Section 153A was improperly assumed in the absence of incriminating material for the relevant year, rendering the assessment under Section 153A invalid. The appeal was allowed to the extent of deleting the additions and quashing the Section 153A assessment.
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