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 held that where amounts received by an assessee firm are duly recorded in its books and partners affirm introduction of capital, an addition under s. 68 cannot be sustained against the firm; any doubt as to the creditworthiness or genuineness of the source must be investigated qua the individual partner who introduced the funds rather than against the firm. The tribunal concluded that treating partners' capital deployed for land acquisition as unexplained investment vis-Ã -vis the firm was impermissible. Accordingly, the assessing officer's addition was annulled, the appellate authority's contrary finding was set aside, and the firm's corresponding grounds were allowed.
ITAT held that where amounts received by an assessee firm are duly recorded in its books and partners affirm introduction of capital, an addition under s. 68 cannot be sustained against the firm; any doubt as to the creditworthiness or genuineness of the source must be investigated qua the individual partner who introduced the funds rather than against the firm. The tribunal concluded that treating partners' capital deployed for land acquisition as unexplained investment vis-Ã -vis the firm was impermissible. Accordingly, the assessing officer's addition was annulled, the appellate authority's contrary finding was set aside, and the firm's corresponding grounds were allowed.
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