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 upheld deletion of additions under s.10(3) of the BMA and associated penalties under ss.41/43, holding that contemporaneous documents and the assessee's un-retracted s.132(4) statement, corroborated by a third party's affidavit, balance sheets and correspondence found during search, established that credits in foreign entities' bank accounts were withdrawn solely by the third party and not by the assessee. The Tribunal applied the presumptions under s.132(4A) read with s.292C, found them unrebutted, and concluded the foreign companies were distinct legal entities; accordingly the bank account proceeds could not be taxed in the hands of the assessee. Other BMA challenges were left open as unnecessary.
ITAT upheld deletion of additions under s.10(3) of the BMA and associated penalties under ss.41/43, holding that contemporaneous documents and the assessee's un-retracted s.132(4) statement, corroborated by a third party's affidavit, balance sheets and correspondence found during search, established that credits in foreign entities' bank accounts were withdrawn solely by the third party and not by the assessee. The Tribunal applied the presumptions under s.132(4A) read with s.292C, found them unrebutted, and concluded the foreign companies were distinct legal entities; accordingly the bank account proceeds could not be taxed in the hands of the assessee. Other BMA challenges were left open as unnecessary.
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