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 assessing officer's additions disallowing purchases were unsustainable and deleted the impugned additions. The Tribunal found the AO had accepted sales, had not rejected the books of account, and had recorded evidence of payment by account-payee cheques and stock reconciliation statements; the AO produced no evidence of cash being returned to the taxpayer nor conducted any independent verification. Reliance solely on observations of the sales tax department, without independent inquiry, rendered the additions arbitrary. Accordingly, the appeal of the taxpayer was allowed and the assessment adjustments were set aside.
ITAT held that the assessing officer's additions disallowing purchases were unsustainable and deleted the impugned additions. The Tribunal found the AO had accepted sales, had not rejected the books of account, and had recorded evidence of payment by account-payee cheques and stock reconciliation statements; the AO produced no evidence of cash being returned to the taxpayer nor conducted any independent verification. Reliance solely on observations of the sales tax department, without independent inquiry, rendered the additions arbitrary. Accordingly, the appeal of the taxpayer was allowed and the assessment adjustments were set aside.
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