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 allowed the assessee's appeal, holding that additions under section 69A and section 68 were unsustainable. The Tribunal found the addition under s.69A, alleging unexplained investment in land, legally and factually untenable because the impugned sum was not fully paid in the relevant previous year and the investment source was satisfactorily explained by partners' capital contributions. The Tribunal further held that the addition under s.68, premised on alleged unexplained capital introduced by partners, was unjustified since the assessee had established the partners' identity, creditworthiness and the genuineness of the transactions. Consequently, both additions were deleted and the assessment recalibrated accordingly.
ITAT allowed the assessee's appeal, holding that additions under section 69A and section 68 were unsustainable. The Tribunal found the addition under s.69A, alleging unexplained investment in land, legally and factually untenable because the impugned sum was not fully paid in the relevant previous year and the investment source was satisfactorily explained by partners' capital contributions. The Tribunal further held that the addition under s.68, premised on alleged unexplained capital introduced by partners, was unjustified since the assessee had established the partners' identity, creditworthiness and the genuineness of the transactions. Consequently, both additions were deleted and the assessment recalibrated accordingly.
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