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 appeal and deleted the addition under s. 68 relating to unexplained cash deposits, holding that the identity and creditworthiness of the incoming partner and the genuineness of the capital contribution were satisfactorily established. The Tribunal found that consistent substantial bank balances and the cash-in-hand as on 13.10.2016 provided a plausible source for the alleged deposits. Consequently, the finding of the ld. CIT(A) was reversed and the impugned addition was deleted, resulting in allowance of the assessee's grounds of appeal.
ITAT allowed the appeal and deleted the addition under s. 68 relating to unexplained cash deposits, holding that the identity and creditworthiness of the incoming partner and the genuineness of the capital contribution were satisfactorily established. The Tribunal found that consistent substantial bank balances and the cash-in-hand as on 13.10.2016 provided a plausible source for the alleged deposits. Consequently, the finding of the ld. CIT(A) was reversed and the impugned addition was deleted, resulting in allowance of the assessee's grounds of appeal.
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