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 upholds validity of reopening under s.147 of the Income-tax Act, finding that the AO had prima facie material (undisclosed bank account and substantial unexplained deposits during demonetisation) to infer escapement of income; CIT(A)'s detailed reasons were not controverted by the assessee and sanction under s.151 was effectively accorded. Grounds challenging jurisdictional reopening are dismissed. Reassessment was within the four-year period, so proviso to s.147 is inapplicable. Pursuant to the Explanation to s.147, AO possessed authority to examine and assess deposits beyond the original reasons; deposits in one account (partly) and entire deposits in the undisclosed account were held unexplained. Taxability of those deposits is remanded to the AO for fresh adjudication.
ITAT upholds validity of reopening under s.147 of the Income-tax Act, finding that the AO had prima facie material (undisclosed bank account and substantial unexplained deposits during demonetisation) to infer escapement of income; CIT(A)'s detailed reasons were not controverted by the assessee and sanction under s.151 was effectively accorded. Grounds challenging jurisdictional reopening are dismissed. Reassessment was within the four-year period, so proviso to s.147 is inapplicable. Pursuant to the Explanation to s.147, AO possessed authority to examine and assess deposits beyond the original reasons; deposits in one account (partly) and entire deposits in the undisclosed account were held unexplained. Taxability of those deposits is remanded to the AO for fresh adjudication.
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