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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The HC upheld the appellate authority's allowance for the assessee, disallowing the Assessing Officer's addition for unexplained investments and loans. The court found the AO erred by treating the balance-sheet figure as a terminal investment without accounting for the preceding year's closing investments and the documented sale of equity shares reducing the holding. The HC accepted the assessee's explanation that funds derived partly from the sale proceeds and partly from a fresh unsecured loan from related private companies; those loans were evidenced through banking channels and the creditors were registered, taxable private companies. Consequently, additions on account of unexplained investments and loans were quashed in favour of the assessee.
The HC upheld the appellate authority's allowance for the assessee, disallowing the Assessing Officer's addition for unexplained investments and loans. The court found the AO erred by treating the balance-sheet figure as a terminal investment without accounting for the preceding year's closing investments and the documented sale of equity shares reducing the holding. The HC accepted the assessee's explanation that funds derived partly from the sale proceeds and partly from a fresh unsecured loan from related private companies; those loans were evidenced through banking channels and the creditors were registered, taxable private companies. Consequently, additions on account of unexplained investments and loans were quashed in favour of the assessee.
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