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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The HC upheld the concurrent findings of the CIT(A) and ITAT that the AO failed to establish a probative nexus between calculated consumption figures and the presumed suppressed yield; therefore the AO's addition for alleged unaccounted production and sales was arbitrary and speculative. Both appellate authorities, after objective appraisal of the evidentiary material, found no adverse material to impeach the assessee's books or to justify rejection of accounts under s.145(3). In consequence, the addition premised on assumed low yield was set aside and the Revenue's appeal dismissed, the courts treating the AO's exercise as conjectural rather than evidential.
The HC upheld the concurrent findings of the CIT(A) and ITAT that the AO failed to establish a probative nexus between calculated consumption figures and the presumed suppressed yield; therefore the AO's addition for alleged unaccounted production and sales was arbitrary and speculative. Both appellate authorities, after objective appraisal of the evidentiary material, found no adverse material to impeach the assessee's books or to justify rejection of accounts under s.145(3). In consequence, the addition premised on assumed low yield was set aside and the Revenue's appeal dismissed, the courts treating the AO's exercise as conjectural rather than evidential.
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