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 appeal and directed deletion of the addition framed under s. 68. The Tribunal found the addition devoid of merit, observing that the Assessing Officer and the ld. CIT(A) merely reproduced the assessment order without independent application of mind or meaningful inquiry; none of the decisions relied upon by the assessee were distinguished in the appellate order. The assessee had disclosed substantial short-term capital gains and discharged tax of Rs. 6,28,059. On both factual and legal grounds the ITAT concluded the addition could not be sustained and set aside the assessment-stage addition, directing the AO to delete the disputed s. 68 imputation.
ITAT allowed the appeal and directed deletion of the addition framed under s. 68. The Tribunal found the addition devoid of merit, observing that the Assessing Officer and the ld. CIT(A) merely reproduced the assessment order without independent application of mind or meaningful inquiry; none of the decisions relied upon by the assessee were distinguished in the appellate order. The assessee had disclosed substantial short-term capital gains and discharged tax of Rs. 6,28,059. On both factual and legal grounds the ITAT concluded the addition could not be sustained and set aside the assessment-stage addition, directing the AO to delete the disputed s. 68 imputation.
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