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 the CIT(A) erred in deleting additions relating to cryptocurrency purchases and unexplained cash credits under s.68, set aside the appellate order and reinstated the AO's findings. The Tribunal noted the assessee failed to furnish documentary evidence for local purchases, admitted audit coverage was limited to Zebpay transactions, and failed to substantiate transactions or furnish requisite particulars despite opportunities. Given these lacunae, the deletions by CIT(A) were unjustified; accordingly the AO's additions are restored and the matter returns to the assessment record for action consistent with the AO's findings.
ITAT held that the CIT(A) erred in deleting additions relating to cryptocurrency purchases and unexplained cash credits under s.68, set aside the appellate order and reinstated the AO's findings. The Tribunal noted the assessee failed to furnish documentary evidence for local purchases, admitted audit coverage was limited to Zebpay transactions, and failed to substantiate transactions or furnish requisite particulars despite opportunities. Given these lacunae, the deletions by CIT(A) were unjustified; accordingly the AO's additions are restored and the matter returns to the assessment record for action consistent with the AO's findings.
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