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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT sustained a restricted addition of Rs. 4,65,000 to the assessee's income for A.Y. 2015-16, applying a 25% estimation rate to the net alleged unaccounted expenditure derived from the seized diary. The Tribunal held that the AO's aggregation of only positive diary balances without third-party verification led to potential overstatement; accordingly, a calibrated discount was warranted to account for duplications, negative balances, vendor confirmations produced on appeal, valuation evidence indicating lower total cost than accounted payments, and absence of AO inquiries under section 131/133(6). No separate addition was sustained for A.Y. 2016-17.
ITAT sustained a restricted addition of Rs. 4,65,000 to the assessee's income for A.Y. 2015-16, applying a 25% estimation rate to the net alleged unaccounted expenditure derived from the seized diary. The Tribunal held that the AO's aggregation of only positive diary balances without third-party verification led to potential overstatement; accordingly, a calibrated discount was warranted to account for duplications, negative balances, vendor confirmations produced on appeal, valuation evidence indicating lower total cost than accounted payments, and absence of AO inquiries under section 131/133(6). No separate addition was sustained for A.Y. 2016-17.
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