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 allowed the appeal of the assessee, holding that additions under section 69A read with section 115BBE based solely on bank cash deposits were unsustainable where the assessee had declared income under presumptive taxation u/s 44AD and was not obliged to maintain detailed books. The Tribunal accepted contemporaneous cash-flow statements, month-wise cash sales and deposit analyses, and comparative business trends showing proportionate growth and heightened cash activity surrounding demonetisation. Given the jewellery-trading nature in a rural area with limited digital infrastructure and absence of any specific incriminating material from the Revenue disproving the explanations, the AO's addition was deleted and the reassessment based on unexplained cash deposits dismissed.
ITAT allowed the appeal of the assessee, holding that additions under section 69A read with section 115BBE based solely on bank cash deposits were unsustainable where the assessee had declared income under presumptive taxation u/s 44AD and was not obliged to maintain detailed books. The Tribunal accepted contemporaneous cash-flow statements, month-wise cash sales and deposit analyses, and comparative business trends showing proportionate growth and heightened cash activity surrounding demonetisation. Given the jewellery-trading nature in a rural area with limited digital infrastructure and absence of any specific incriminating material from the Revenue disproving the explanations, the AO's addition was deleted and the reassessment based on unexplained cash deposits dismissed.
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