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 held that the unexplained cash deposits in the assessee's bank account were attributable to the business of buying and selling mosquito nets, supported by purchase and sales records and bank statements. The Tribunal found that the CIT(A) erred in treating all credits as unexplained income under section 69A without considering the nature of the business. However, due to the absence of proper books of account, the Tribunal accepted an average net profit rate of 12% on the cash deposits, based on historical profit percentages from prior assessment years. Consequently, the addition of the entire amount as unexplained income was set aside, and only a proportionate addition reflecting 12% net profit was upheld, ensuring a fair and reasonable assessment in line with the principles of presumptive taxation.
The ITAT held that the unexplained cash deposits in the assessee's bank account were attributable to the business of buying and selling mosquito nets, supported by purchase and sales records and bank statements. The Tribunal found that the CIT(A) erred in treating all credits as unexplained income under section 69A without considering the nature of the business. However, due to the absence of proper books of account, the Tribunal accepted an average net profit rate of 12% on the cash deposits, based on historical profit percentages from prior assessment years. Consequently, the addition of the entire amount as unexplained income was set aside, and only a proportionate addition reflecting 12% net profit was upheld, ensuring a fair and reasonable assessment in line with the principles of presumptive taxation.
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