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 rejection of the appellant's audited books under section 145(3) due to failure to furnish any documentary evidence substantiating the correctness of the return or details of inventory clearance following the firm's dissolution. The AO's estimation of income based on 25% of inventory value, reduced from 50%, was affirmed as a reasonable approximation in light of absent records such as stock movement, sales invoices, and bank statements. The appellant's failure to prosecute the appeal before the NFAC and non-compliance with procedural notices further weakened its position. The Tribunal found no merit in the appellant's claims regarding forced stock clearance and ongoing disputes, concluding that the ad-hoc estimations by the tax authorities were justified given the market conditions and appellant's conduct. Consequently, the appeal was dismissed and the impugned order was upheld in its entirety.
The ITAT upheld the rejection of the appellant's audited books under section 145(3) due to failure to furnish any documentary evidence substantiating the correctness of the return or details of inventory clearance following the firm's dissolution. The AO's estimation of income based on 25% of inventory value, reduced from 50%, was affirmed as a reasonable approximation in light of absent records such as stock movement, sales invoices, and bank statements. The appellant's failure to prosecute the appeal before the NFAC and non-compliance with procedural notices further weakened its position. The Tribunal found no merit in the appellant's claims regarding forced stock clearance and ongoing disputes, concluding that the ad-hoc estimations by the tax authorities were justified given the market conditions and appellant's conduct. Consequently, the appeal was dismissed and the impugned order was upheld in its entirety.
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