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 affirmed deletion of additions against the assessee, holding that the limbs of s.69A were not satisfied where no cash, bullion, jewellery or other incriminating assets were found and no reliable money trail linked the impounded booking forms to undisclosed receipts. Additions under s.69C based on differences between estimated booking values and sale deed consideration were also deleted where there was no evidence of genuine customer bookings and no corroboration of on-money receipts. The Tribunal found the AO failed to produce corroborative evidence or properly examine customers, and relied on loose papers and electronic material without requisite evidentiary foundation, thereby deciding against the revenue.
ITAT affirmed deletion of additions against the assessee, holding that the limbs of s.69A were not satisfied where no cash, bullion, jewellery or other incriminating assets were found and no reliable money trail linked the impounded booking forms to undisclosed receipts. Additions under s.69C based on differences between estimated booking values and sale deed consideration were also deleted where there was no evidence of genuine customer bookings and no corroboration of on-money receipts. The Tribunal found the AO failed to produce corroborative evidence or properly examine customers, and relied on loose papers and electronic material without requisite evidentiary foundation, thereby deciding against the revenue.
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