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 set aside the addition of Rs. 1 crore made by the AO on account of unverified purchases, holding that the assessee had furnished adequate details, including purchase and sales invoices, sundry creditors exceeding Rs. 1 lakh with full particulars, and no defect was pointed out by the AO. The tribunal found the addition unjustified and ruled in favor of the assessee. Further, the addition under section 68 read with section 115BBE related to advances from customers was deleted, as the assessee rectified the erroneous classification of a loan as an advance through journal entries. Regarding the addition under section 69A for unexplained cash deposits, the tribunal accepted the assessee's explanation supported by cash books, sales registers, VAT returns, and bank records, confirming the deposits originated from cash sales and opening balances. All impugned additions were thus deleted, favoring the assessee.
The ITAT set aside the addition of Rs. 1 crore made by the AO on account of unverified purchases, holding that the assessee had furnished adequate details, including purchase and sales invoices, sundry creditors exceeding Rs. 1 lakh with full particulars, and no defect was pointed out by the AO. The tribunal found the addition unjustified and ruled in favor of the assessee. Further, the addition under section 68 read with section 115BBE related to advances from customers was deleted, as the assessee rectified the erroneous classification of a loan as an advance through journal entries. Regarding the addition under section 69A for unexplained cash deposits, the tribunal accepted the assessee's explanation supported by cash books, sales registers, VAT returns, and bank records, confirming the deposits originated from cash sales and opening balances. All impugned additions were thus deleted, favoring the assessee.
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