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 determination that the unexplained credit amounting to Rs. 1,92,55,560/- was not entirely taxable as income under section 69A, given the assessee's failure to file a return for the relevant year and the nature of the business. The CIT(A) accepted additional evidence furnished under rule 46A and quantified income at 8% on turnover under section 44AD, rather than treating the entire credit as income. The AO failed to comment on the remand report and did not dispute the third-party affidavit evidence supporting the assessee's claim. Consequently, the tribunal found no merit in the revenue's grounds and allowed the assessee's appeal, confirming that income computation based on the affidavit and supporting evidence was appropriate.
The ITAT upheld the CIT(A)'s determination that the unexplained credit amounting to Rs. 1,92,55,560/- was not entirely taxable as income under section 69A, given the assessee's failure to file a return for the relevant year and the nature of the business. The CIT(A) accepted additional evidence furnished under rule 46A and quantified income at 8% on turnover under section 44AD, rather than treating the entire credit as income. The AO failed to comment on the remand report and did not dispute the third-party affidavit evidence supporting the assessee's claim. Consequently, the tribunal found no merit in the revenue's grounds and allowed the assessee's appeal, confirming that income computation based on the affidavit and supporting evidence was appropriate.
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