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...
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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 of the assessee and deleted additions under ss. 69A, 69 and 69C. The Tribunal held that documentary evidence (including a VDIS certificate, notarised wills and stamped agreements) and family member statements satisfactorily explained jewellery seized during search; AO's treatment of specified jewellery as unexplained was unjustified. The Tribunal further found the house-construction addition to be based on mere presumption as contractor bills lacked proof of payment and the admitted settled amount recorded in books was supported by documents. Finally, household-expense addition based on a diary in the wife's handwriting was rebutted by recorded family withdrawals. ITAT set aside CIT(A)'s findings and directed the AO to delete the respective additions.
ITAT allowed the appeal of the assessee and deleted additions under ss. 69A, 69 and 69C. The Tribunal held that documentary evidence (including a VDIS certificate, notarised wills and stamped agreements) and family member statements satisfactorily explained jewellery seized during search; AO's treatment of specified jewellery as unexplained was unjustified. The Tribunal further found the house-construction addition to be based on mere presumption as contractor bills lacked proof of payment and the admitted settled amount recorded in books was supported by documents. Finally, household-expense addition based on a diary in the wife's handwriting was rebutted by recorded family withdrawals. ITAT set aside CIT(A)'s findings and directed the AO to delete the respective additions.
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