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 that the impugned addition under assessment proceedings is unsustainable. The assessee demonstrated that the disputed receipts arose from GST invoices dated 12.4.2018 and 12.5.2018, declared in GSTR-1 and reflected in an updated Form 26AS, with corresponding tax deducted at source by the payer in FY 2017-18 (AY 2018-19). The Tribunal finds the receipts were correctly offered to tax in AY 2019-20, are revenue-neutral vis-Ã -vis matching TDS, and do not pertain to the assessment year under challenge. Consequently the addition is deleted and the assessee's appeal against the AO's assessment is allowed.
ITAT upholds that the impugned addition under assessment proceedings is unsustainable. The assessee demonstrated that the disputed receipts arose from GST invoices dated 12.4.2018 and 12.5.2018, declared in GSTR-1 and reflected in an updated Form 26AS, with corresponding tax deducted at source by the payer in FY 2017-18 (AY 2018-19). The Tribunal finds the receipts were correctly offered to tax in AY 2019-20, are revenue-neutral vis-Ã -vis matching TDS, and do not pertain to the assessment year under challenge. Consequently the addition is deleted and the assessee's appeal against the AO's assessment is allowed.
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