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 ITAT allowed the appeal, holding that additions under section 68 could not be sustained where the assessee's cash bank deposits were supported by recorded cash sales in audited books which the AO had not disputed. The Tribunal found the AO's partial acceptance and partial rejection of the same evidentiary material to be based on surmise and conjecture, resulting in double taxation since sales already reflected in income were again treated as unexplained credits. The records, including stock and purchase accounts, were not impugned by Revenue and the cash receipts-occurring pre-demonetization during festival period-were held to emanate from genuine business sales, thus disallowing the section 68 addition.
The ITAT allowed the appeal, holding that additions under section 68 could not be sustained where the assessee's cash bank deposits were supported by recorded cash sales in audited books which the AO had not disputed. The Tribunal found the AO's partial acceptance and partial rejection of the same evidentiary material to be based on surmise and conjecture, resulting in double taxation since sales already reflected in income were again treated as unexplained credits. The records, including stock and purchase accounts, were not impugned by Revenue and the cash receipts-occurring pre-demonetization during festival period-were held to emanate from genuine business sales, thus disallowing the section 68 addition.
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