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 set aside the additions made by the AO under sections 68 and 69C relating to unexplained cash credits, bogus commission, and bogus interest on unsecured loans, as the assessee had repaid the loans in the subsequent year and the department had accepted such repayments without making additions. The AO's reliance on unrecorded statements under section 131 and failure to demonstrate escaped income or assets as required under the fourth proviso to section 153A for reopening assessments beyond six years rendered the reassessment invalid. Since the AO did not fulfill statutory conditions for invoking extended limitation under section 153A for the eighth assessment year from the search year, the reopening was held without jurisdiction. Consequently, the ITAT allowed the assessee's appeal, quashing the additions and the reassessment proceedings.
The ITAT set aside the additions made by the AO under sections 68 and 69C relating to unexplained cash credits, bogus commission, and bogus interest on unsecured loans, as the assessee had repaid the loans in the subsequent year and the department had accepted such repayments without making additions. The AO's reliance on unrecorded statements under section 131 and failure to demonstrate escaped income or assets as required under the fourth proviso to section 153A for reopening assessments beyond six years rendered the reassessment invalid. Since the AO did not fulfill statutory conditions for invoking extended limitation under section 153A for the eighth assessment year from the search year, the reopening was held without jurisdiction. Consequently, the ITAT allowed the assessee's appeal, quashing the additions and the reassessment proceedings.
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