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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT allowed the appeal and deleted the additions. The Tribunal held there was no cogent evidence of remission or cessation of liability under s.41(1), noting commission entries were not actually paid and books corroborated that position; PANs and account particulars of third parties were produced and mere non-response to s.133(6) notices did not justify additions absent verification by the respective AOs. The cash-deposit addition was also rejected: bank statements, cash book and earlier financials established the deposits derived from withdrawals and disposal of prior-business assets, and the AO failed to examine these records. Both disputed additions were therefore deleted and grounds allowed in favour of the assessee.
ITAT allowed the appeal and deleted the additions. The Tribunal held there was no cogent evidence of remission or cessation of liability under s.41(1), noting commission entries were not actually paid and books corroborated that position; PANs and account particulars of third parties were produced and mere non-response to s.133(6) notices did not justify additions absent verification by the respective AOs. The cash-deposit addition was also rejected: bank statements, cash book and earlier financials established the deposits derived from withdrawals and disposal of prior-business assets, and the AO failed to examine these records. Both disputed additions were therefore deleted and grounds allowed in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.