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...
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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 holds that the approving authority's mechanical approval under section 153D does not preclude substantive consideration; on facts the assessee's revised return declaring 14-15% profit is accepted because group net profit computed from seized and books material is 1.47%, substantially below declared rates and prior-year margins, hence no further addition warranted and impugned additions are deleted, allowing the assessee's cross-objection and dismissing the revenue's appeal. The CIT(A)'s rejection of AO's unsupported agricultural income estimate is upheld on documentary proof (J-forms, khasra/khatauni). Unsecured loans are treated as genuine under section 68 on furnished confirmations, PANs and ITRs; related additions are deleted and revenue's grounds dismissed.
ITAT holds that the approving authority's mechanical approval under section 153D does not preclude substantive consideration; on facts the assessee's revised return declaring 14-15% profit is accepted because group net profit computed from seized and books material is 1.47%, substantially below declared rates and prior-year margins, hence no further addition warranted and impugned additions are deleted, allowing the assessee's cross-objection and dismissing the revenue's appeal. The CIT(A)'s rejection of AO's unsupported agricultural income estimate is upheld on documentary proof (J-forms, khasra/khatauni). Unsecured loans are treated as genuine under section 68 on furnished confirmations, PANs and ITRs; related additions are deleted and revenue's grounds dismissed.
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