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 dismissed the plea of violation of natural justice, holding that the assessee was given ample opportunity to explain discrepancies in books and bank statements but failed to provide cogent evidence. Although the AO did not formally reject the books under section 145(3), the assessment under section 144 was upheld as valid due to mismatches found and proper procedural compliance. Additions under section 69A for unexplained cash deposits were partly disallowed, as the tribunal found that taxing the same amount twice was unjustified; instead, profits were to be computed at 7.99% of total bank credits. Consequently, additions under sections 69A and 69C were deleted, and section 115BBE was held inapplicable. Regarding undisclosed credits from a purported property sale, the matter was remitted to the AO for fresh adjudication with directions to assess capital gains and verify evidence submitted by the assessee.
The ITAT dismissed the plea of violation of natural justice, holding that the assessee was given ample opportunity to explain discrepancies in books and bank statements but failed to provide cogent evidence. Although the AO did not formally reject the books under section 145(3), the assessment under section 144 was upheld as valid due to mismatches found and proper procedural compliance. Additions under section 69A for unexplained cash deposits were partly disallowed, as the tribunal found that taxing the same amount twice was unjustified; instead, profits were to be computed at 7.99% of total bank credits. Consequently, additions under sections 69A and 69C were deleted, and section 115BBE was held inapplicable. Regarding undisclosed credits from a purported property sale, the matter was remitted to the AO for fresh adjudication with directions to assess capital gains and verify evidence submitted by the assessee.
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