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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...
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Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT upheld validity of reopening, finding that approval under s.151 was recorded on the ITBA on 29.03.2018 and thereby authorised issuance of notice under s.148, rejecting the assessee's challenge to reopening. On merits, ITAT recognised PBPT adjudication holding the transaction benami and identifying multiple beneficial owners; consequently ITAT held the entire addition could not be charged solely to the assessee under s.69 and directed restoration to the AO for re-adjudication and allocation of unexplained investment among joint beneficial owners in accordance with PBPT orders. The appellate order of CIT(A) was set aside, and reliance on incomplete VSVS filings was held not to be a conclusive admission.
ITAT upheld validity of reopening, finding that approval under s.151 was recorded on the ITBA on 29.03.2018 and thereby authorised issuance of notice under s.148, rejecting the assessee's challenge to reopening. On merits, ITAT recognised PBPT adjudication holding the transaction benami and identifying multiple beneficial owners; consequently ITAT held the entire addition could not be charged solely to the assessee under s.69 and directed restoration to the AO for re-adjudication and allocation of unexplained investment among joint beneficial owners in accordance with PBPT orders. The appellate order of CIT(A) was set aside, and reliance on incomplete VSVS filings was held not to be a conclusive admission.
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