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 validity of reassessment proceedings initiated under s.147 by notice under s.148, finding no infirmity in reopening based on documents seized from a third party and dismissing the challenge that proceedings should have been under ss.153A/153C. However, ITAT found the substantive additions for alleged cash receipts unsustainable: seized papers did not bear the assessee's name, no corroborative evidence linked the entries to the assessee, and the disputed Rs.5,00,000 was shown returned to a related group company with bank records and no proof of cash receipt by the assessee. AO was directed to delete the additions; respective grounds of appeal were allowed.
ITAT upheld the validity of reassessment proceedings initiated under s.147 by notice under s.148, finding no infirmity in reopening based on documents seized from a third party and dismissing the challenge that proceedings should have been under ss.153A/153C. However, ITAT found the substantive additions for alleged cash receipts unsustainable: seized papers did not bear the assessee's name, no corroborative evidence linked the entries to the assessee, and the disputed Rs.5,00,000 was shown returned to a related group company with bank records and no proof of cash receipt by the assessee. AO was directed to delete the additions; respective grounds of appeal were allowed.
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