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 vacated and set aside the addition of Rs. 5.19 crore made by the AO under ss. 69A/69C, holding that the impugned quantitative discrepancies in purchases, sales and closing stock arose from the AO's failure to appreciate that the opening stock of the parent item included branded sub-stock, and from adoption of distorted figures. The Tribunal found the assessee's VAT return summaries corroborated the reported purchases and sales for FY 2016-17 and concluded the AO's adverse inferences lacked basis. Consequently, the CIT(A)'s order sustaining the addition was quashed and the appeal of the assessee was allowed, with the impugned assessment addition vacated.
ITAT vacated and set aside the addition of Rs. 5.19 crore made by the AO under ss. 69A/69C, holding that the impugned quantitative discrepancies in purchases, sales and closing stock arose from the AO's failure to appreciate that the opening stock of the parent item included branded sub-stock, and from adoption of distorted figures. The Tribunal found the assessee's VAT return summaries corroborated the reported purchases and sales for FY 2016-17 and concluded the AO's adverse inferences lacked basis. Consequently, the CIT(A)'s order sustaining the addition was quashed and the appeal of the assessee was allowed, with the impugned assessment addition vacated.
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