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 reopening of assessment under section 147 as valid, finding the reasons recorded for issuing the notice within the four-year period to be justified. The addition under section 69A relating to a cash deposit of Rs. 8,00,000 during the demonetization period was deleted, as the assessee satisfactorily explained the source as cash sales supported by consistent business records. However, the Tribunal found the AO's addition on estimated profits from alleged suppressed purchases erroneous, noting the correct purchase amount was already accounted for. Consequently, the addition of Rs. 13,07,642 was deleted, and the assessee's ground challenging this addition was allowed.
The ITAT upheld the reopening of assessment under section 147 as valid, finding the reasons recorded for issuing the notice within the four-year period to be justified. The addition under section 69A relating to a cash deposit of Rs. 8,00,000 during the demonetization period was deleted, as the assessee satisfactorily explained the source as cash sales supported by consistent business records. However, the Tribunal found the AO's addition on estimated profits from alleged suppressed purchases erroneous, noting the correct purchase amount was already accounted for. Consequently, the addition of Rs. 13,07,642 was deleted, and the assessee's ground challenging this addition was allowed.
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