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 allowed the assessee's appeal and deleted the addition under section 56(2) arising from a purported gift, holding that the amount received from the spouse of the assessee's sister falls within the definition of "relative" and is therefore exempt. The Tribunal found the remitted funds were routed through normal banking channels and documentary evidence of the source was furnished; no statutory requirement for a formal gift deed exists for movable property nor for exemption under section 56(2), and the Gift Tax Act is not in operation. The AO's characterization of the receipt as income from other sources was reversed; any tax consequence, if relevant, would lie in the hands of the donor, not the assessee.
ITAT allowed the assessee's appeal and deleted the addition under section 56(2) arising from a purported gift, holding that the amount received from the spouse of the assessee's sister falls within the definition of "relative" and is therefore exempt. The Tribunal found the remitted funds were routed through normal banking channels and documentary evidence of the source was furnished; no statutory requirement for a formal gift deed exists for movable property nor for exemption under section 56(2), and the Gift Tax Act is not in operation. The AO's characterization of the receipt as income from other sources was reversed; any tax consequence, if relevant, would lie in the hands of the donor, not the assessee.
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