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 upheld the assessee's claim regarding unexplained cash credits under section 68, rejecting the revenue's addition of alleged bogus unsecured loans. The assessee discharged the onus by furnishing ledger accounts, audited financial statements, bank records, ITR acknowledgments, and sale bills, thereby establishing the identity, capacity, and genuineness of the creditors and transactions. The tribunal further held that a retracted statement recorded during survey/search proceedings could not form the basis for making any addition. Consequently, the ITAT dismissed the revenue's appeal, affirming that the assessee satisfactorily met the evidentiary requirements to rebut the deeming provisions under section 68.
The ITAT upheld the assessee's claim regarding unexplained cash credits under section 68, rejecting the revenue's addition of alleged bogus unsecured loans. The assessee discharged the onus by furnishing ledger accounts, audited financial statements, bank records, ITR acknowledgments, and sale bills, thereby establishing the identity, capacity, and genuineness of the creditors and transactions. The tribunal further held that a retracted statement recorded during survey/search proceedings could not form the basis for making any addition. Consequently, the ITAT dismissed the revenue's appeal, affirming that the assessee satisfactorily met the evidentiary requirements to rebut the deeming provisions under section 68.
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