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...
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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 deletion of additions made on account of alleged undisclosed sales and unexplained stock transfers by the AO. The AO's reliance on CCTV footage from a single day to extrapolate suppressed sales throughout the year was deemed speculative and lacking a reasonable basis, unsupported by corroborative evidence. The assessee's books of account, including cash books and sales registers for both the Mumbai HO and Cuttack branch, were found to be accurate and reliable. Regarding the stock transfer of 27 kgs. of gold ornaments between branches, the tribunal noted proper reconciliation through statutory Form F and consistent accounting entries, rejecting reliance on contradictory statements and uncorroborated airline information. The absence of any adverse findings by Sales Tax authorities further supported the assessee's case. Consequently, the ITAT affirmed the appellate authority's decision deleting the additions, ruling in favor of the assessee.
The ITAT upheld the deletion of additions made on account of alleged undisclosed sales and unexplained stock transfers by the AO. The AO's reliance on CCTV footage from a single day to extrapolate suppressed sales throughout the year was deemed speculative and lacking a reasonable basis, unsupported by corroborative evidence. The assessee's books of account, including cash books and sales registers for both the Mumbai HO and Cuttack branch, were found to be accurate and reliable. Regarding the stock transfer of 27 kgs. of gold ornaments between branches, the tribunal noted proper reconciliation through statutory Form F and consistent accounting entries, rejecting reliance on contradictory statements and uncorroborated airline information. The absence of any adverse findings by Sales Tax authorities further supported the assessee's case. Consequently, the ITAT affirmed the appellate authority's decision deleting the additions, ruling in favor of the assessee.
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