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...
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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 upheld the order of CIT(A) and dismissed Revenue's appeals, rejecting additions under s.68 and s.69C. The Tribunal found the assessee had furnished corroborative documentary evidence - ledger extracts, sales register, invoices, bank statements, e-way bills, transport details and VAT returns - demonstrating genuine sales recorded in books. The AO's additions rested solely on an isolated statement of a third party without independent corroborative or substantive material, and AO did not controvert the documentary evidence. Accordingly, the Tribunal held the AO's reliance on the investigation wing's finding that a purchaser was bogus was insufficient to sustain additions, and directed deletion of the impugned additions.
ITAT upheld the order of CIT(A) and dismissed Revenue's appeals, rejecting additions under s.68 and s.69C. The Tribunal found the assessee had furnished corroborative documentary evidence - ledger extracts, sales register, invoices, bank statements, e-way bills, transport details and VAT returns - demonstrating genuine sales recorded in books. The AO's additions rested solely on an isolated statement of a third party without independent corroborative or substantive material, and AO did not controvert the documentary evidence. Accordingly, the Tribunal held the AO's reliance on the investigation wing's finding that a purchaser was bogus was insufficient to sustain additions, and directed deletion of the impugned additions.
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