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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The ITAT upheld reassessment under s.147, finding the AO's formation of belief was based on independent, cogent material from the Investigation Wing and not on borrowed satisfaction; the reopening was procedurally and substantively justified. The Tribunal sustained the AO's s.68 addition treating alleged LTCG as unexplained income, noting the assessee failed to discharge the onus to prove genuineness of massive acquisition of shares in an entity lacking commercial and financial credentials. Documentary proofs alone (contract notes, demat extracts, bank payments) were insufficient in light of surrounding circumstances, manipulated trading patterns and absence of commercial substance, leading the ITAT to dismiss the assessee's appeal.
The ITAT upheld reassessment under s.147, finding the AO's formation of belief was based on independent, cogent material from the Investigation Wing and not on borrowed satisfaction; the reopening was procedurally and substantively justified. The Tribunal sustained the AO's s.68 addition treating alleged LTCG as unexplained income, noting the assessee failed to discharge the onus to prove genuineness of massive acquisition of shares in an entity lacking commercial and financial credentials. Documentary proofs alone (contract notes, demat extracts, bank payments) were insufficient in light of surrounding circumstances, manipulated trading patterns and absence of commercial substance, leading the ITAT to dismiss the assessee's appeal.
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