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 deleted the addition under s.69A and allowed the taxpayer's grounds, holding that the hypothecation of livestock was immaterial once the loan was repaid and could not sustain a presumption of unexplained income. The Tribunal accepted the taxpayer's evidence of livestock sales - including purchaser confirmations with identity documents - and found the Revenue failed to undertake any independent enquiry or produce material impugning purchasers' creditworthiness. Having accepted the taxpayer's net cash flow and that cash deposited during the demonetisation period derived from livestock sales, the Tribunal reversed the CIT(A)'s balance addition and directed deletion of the impugned s.69A assessment.
ITAT deleted the addition under s.69A and allowed the taxpayer's grounds, holding that the hypothecation of livestock was immaterial once the loan was repaid and could not sustain a presumption of unexplained income. The Tribunal accepted the taxpayer's evidence of livestock sales - including purchaser confirmations with identity documents - and found the Revenue failed to undertake any independent enquiry or produce material impugning purchasers' creditworthiness. Having accepted the taxpayer's net cash flow and that cash deposited during the demonetisation period derived from livestock sales, the Tribunal reversed the CIT(A)'s balance addition and directed deletion of the impugned s.69A assessment.
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