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 the CIT(A)'s deletion of an addition under s. 69C, finding the AO's treatment legally unsustainable. The AO ignored comprehensive documentary evidence submitted by the assessee - ledger entries, supplier invoices, delivery challans, inventory registers, bank remittances, vehicle entry/exit records, lorry receipts and warehouse log books - and did not dispute their veracity. The tribunal noted the supplier's GST cancellation postdated the challenged purchases, undermining the AO's sham-transaction assertion. Given the assessee's substantiation and the AO's failure to engage with or controvert the evidence, ITAT confirmed that the addition was unjustified and upheld relief granted by the CIT(A).
ITAT upheld the CIT(A)'s deletion of an addition under s. 69C, finding the AO's treatment legally unsustainable. The AO ignored comprehensive documentary evidence submitted by the assessee - ledger entries, supplier invoices, delivery challans, inventory registers, bank remittances, vehicle entry/exit records, lorry receipts and warehouse log books - and did not dispute their veracity. The tribunal noted the supplier's GST cancellation postdated the challenged purchases, undermining the AO's sham-transaction assertion. Given the assessee's substantiation and the AO's failure to engage with or controvert the evidence, ITAT confirmed that the addition was unjustified and upheld relief granted by the CIT(A).
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