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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT upheld the CIT(A)'s deletion of additions based on bogus purchases, ruling that statements of witnesses not subjected to cross-examination cannot be used against the assessee. Exclusion of such statements left no material for the AO to justify additions, leading to dismissal of the Revenue's appeals. Regarding reassessment, the AO validly formed a prima facie belief of escaped income based on credible information from the ADIT (Investigation), justifying reopening the assessments. The Tribunal found no infirmity in the reopening and accordingly rejected the assessee's cross objections. Thus, the final outcome confirms the validity of reassessment proceedings while negating additions due to inadmissible evidence, resulting in dismissal of the Revenue's appeals and rejection of the assessee's cross objections.
The ITAT upheld the CIT(A)'s deletion of additions based on bogus purchases, ruling that statements of witnesses not subjected to cross-examination cannot be used against the assessee. Exclusion of such statements left no material for the AO to justify additions, leading to dismissal of the Revenue's appeals. Regarding reassessment, the AO validly formed a prima facie belief of escaped income based on credible information from the ADIT (Investigation), justifying reopening the assessments. The Tribunal found no infirmity in the reopening and accordingly rejected the assessee's cross objections. Thus, the final outcome confirms the validity of reassessment proceedings while negating additions due to inadmissible evidence, resulting in dismissal of the Revenue's appeals and rejection of the assessee's cross objections.
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