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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ITAT allowed the assessee's appeal and deleted the additions under s. 69. The Tribunal held that the impugned property's total purchase consideration was Rs. 45,47,701, of which the assessee, as 50% co-owner, only bore Rs. 22,73,850. The assessee satisfactorily explained Rs. 22,00,000 of that share; the remaining Rs. 73,850 was plausibly attributable to cash-in-hand disclosed in the return relating to dairy income and could have been called for explanation by the AO. The AO's blanket addition of the entire investment was therefore found unjustified and set aside.
ITAT allowed the assessee's appeal and deleted the additions under s. 69. The Tribunal held that the impugned property's total purchase consideration was Rs. 45,47,701, of which the assessee, as 50% co-owner, only bore Rs. 22,73,850. The assessee satisfactorily explained Rs. 22,00,000 of that share; the remaining Rs. 73,850 was plausibly attributable to cash-in-hand disclosed in the return relating to dairy income and could have been called for explanation by the AO. The AO's blanket addition of the entire investment was therefore found unjustified and set aside.
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