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 addition of unexplained investment, holding that the assessee (anonymized) failed to substantiate the source of funds for acquisition of immovable property for A.Y. 2016-17. The Tribunal found the unregistered agreement to sell inconsistent with bank evidence, noting purported receipt of consideration at the agreement date conflicted with actual cheque payments in July 2015, undermining documentary credibility. Further, the existence of an earlier joint development agreement and a supplementary agreement demarcating shares meant the developer lacked a definite sellable area before April 2012, rendering alleged payments prior to that date unverifiable. Consequently the assessee's claim was rejected and the assessment sustained against the assessee.
ITAT upheld the addition of unexplained investment, holding that the assessee (anonymized) failed to substantiate the source of funds for acquisition of immovable property for A.Y. 2016-17. The Tribunal found the unregistered agreement to sell inconsistent with bank evidence, noting purported receipt of consideration at the agreement date conflicted with actual cheque payments in July 2015, undermining documentary credibility. Further, the existence of an earlier joint development agreement and a supplementary agreement demarcating shares meant the developer lacked a definite sellable area before April 2012, rendering alleged payments prior to that date unverifiable. Consequently the assessee's claim was rejected and the assessment sustained against the assessee.
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