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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT upheld the addition under section 68, holding that the assessee failed to establish the creditworthiness of the lender and the genuineness of the loan transaction. The lender's bank account was reopened without adherence to KYC norms, and the assessee did not provide essential details such as the lender's address or PAN, despite the lender becoming a shareholder. The cash deposit and immediate transfer to the assessee, coupled with the lender's non-resident status and lack of verifiable income source, undermined the claimed loan's authenticity. The tribunal affirmed the validity of the reassessment notice, noting that the reopening was based on tangible material indicating prima facie escapement of income and was sanctioned by competent authority. The assessee's contention that source of source need not be proved was rejected, as it failed to prove even the primary source of the unsecured loan.
The ITAT upheld the addition under section 68, holding that the assessee failed to establish the creditworthiness of the lender and the genuineness of the loan transaction. The lender's bank account was reopened without adherence to KYC norms, and the assessee did not provide essential details such as the lender's address or PAN, despite the lender becoming a shareholder. The cash deposit and immediate transfer to the assessee, coupled with the lender's non-resident status and lack of verifiable income source, undermined the claimed loan's authenticity. The tribunal affirmed the validity of the reassessment notice, noting that the reopening was based on tangible material indicating prima facie escapement of income and was sanctioned by competent authority. The assessee's contention that source of source need not be proved was rejected, as it failed to prove even the primary source of the unsecured loan.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
