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 held that the adhoc addition of 10% of turnover based on service-tax receipts was unsustainable: the assessee had filed a reconciliation and supporting documents demonstrating legitimate differences between service-tax receipts (advances) and gross receipts for income-tax purposes, and AO and CIT(A) erred in making unreasoned, estimation-based additions. The Tribunal deleted the estimated profit addition and confirmed that books were not rejected nor additional evidence improperly excluded. Disallowance of sales-promotion expenditure was reversed for lack of material showing non-business purpose. Disallowance under section 14A was also deleted on findings that the assessee earned no exempt income in the year.
ITAT held that the adhoc addition of 10% of turnover based on service-tax receipts was unsustainable: the assessee had filed a reconciliation and supporting documents demonstrating legitimate differences between service-tax receipts (advances) and gross receipts for income-tax purposes, and AO and CIT(A) erred in making unreasoned, estimation-based additions. The Tribunal deleted the estimated profit addition and confirmed that books were not rejected nor additional evidence improperly excluded. Disallowance of sales-promotion expenditure was reversed for lack of material showing non-business purpose. Disallowance under section 14A was also deleted on findings that the assessee earned no exempt income in the year.
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