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 upheld the order of the CIT(A) dismissing the revenue's appeal and directing deletion of additions under section 68 read with section 115BBE and section 69C. The Tribunal held that the AO mechanically relied on an investigation report without conducting independent inquiry or identifying any discrepancy in the assessee's documentary and banking proofs for share purchases and sales executed on the stock exchange. SEBI's probe did not name the assessee nor encompass the dates of the assessee's transactions, and the CIT(A)'s reasoned, speaking order correctly found absence of material infirmity in the evidence to sustain the addition; revenue's appeal was therefore dismissed.
ITAT upheld the order of the CIT(A) dismissing the revenue's appeal and directing deletion of additions under section 68 read with section 115BBE and section 69C. The Tribunal held that the AO mechanically relied on an investigation report without conducting independent inquiry or identifying any discrepancy in the assessee's documentary and banking proofs for share purchases and sales executed on the stock exchange. SEBI's probe did not name the assessee nor encompass the dates of the assessee's transactions, and the CIT(A)'s reasoned, speaking order correctly found absence of material infirmity in the evidence to sustain the addition; revenue's appeal was therefore dismissed.
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