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 CIT(A)'s deletion of additions relating to unaccounted sales under the "V" series for AY 2014-15 to 2017-18, rejecting the AO's extrapolation of a 17% unaccounted income ratio from a limited three-month period to earlier years. The Tribunal found the extrapolation speculative and unsupported by corroborative evidence, particularly as the statements relied upon were retracted and no supporting material such as seized data, unexplained investments, or asset acquisitions was found. The books of account were not rejected, rendering the AO's estimation invalid. For AY 2018-19, the AO's claim of suppression beyond the admitted amount was also dismissed due to lack of evidence. Consequently, all revenue appeals were dismissed, affirming the correctness of the CIT(A)'s orders on merit.
The ITAT upheld the CIT(A)'s deletion of additions relating to unaccounted sales under the "V" series for AY 2014-15 to 2017-18, rejecting the AO's extrapolation of a 17% unaccounted income ratio from a limited three-month period to earlier years. The Tribunal found the extrapolation speculative and unsupported by corroborative evidence, particularly as the statements relied upon were retracted and no supporting material such as seized data, unexplained investments, or asset acquisitions was found. The books of account were not rejected, rendering the AO's estimation invalid. For AY 2018-19, the AO's claim of suppression beyond the admitted amount was also dismissed due to lack of evidence. Consequently, all revenue appeals were dismissed, affirming the correctness of the CIT(A)'s orders on merit.
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