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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT set aside the disallowance under section 40A(3) r.w.r 6DD relating to payments made via bearer cheques, holding that the assessee demonstrated the genuineness of payments to laborers, and the AO failed to produce evidence of bogus transactions or non-payment. Consequently, the disallowance by the AO was deleted. Regarding the disallowance of interest expenses treated as attributable to bogus cash credits, the Tribunal partially upheld the CIT(A)'s findings but noted discrepancies concerning interest claimed for certain parties without corresponding loans. The matter was remanded to the AO for further factual verification on these points. Thus, the appeal was partly allowed with directions for reassessment of interest disallowance.
The ITAT set aside the disallowance under section 40A(3) r.w.r 6DD relating to payments made via bearer cheques, holding that the assessee demonstrated the genuineness of payments to laborers, and the AO failed to produce evidence of bogus transactions or non-payment. Consequently, the disallowance by the AO was deleted. Regarding the disallowance of interest expenses treated as attributable to bogus cash credits, the Tribunal partially upheld the CIT(A)'s findings but noted discrepancies concerning interest claimed for certain parties without corresponding loans. The matter was remanded to the AO for further factual verification on these points. Thus, the appeal was partly allowed with directions for reassessment of interest disallowance.
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