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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HC allowed the appeal of the assessee, holding that unsecured loan credited in AY 2014-15 was genuine and not exigible to addition under section 68. The Court found the identity and creditworthiness of the creditor established by bank records and statements recorded under survey and section 133(6); repayments (with interest) through banking channels in the subsequent year corroborated genuineness. The revenue's challenge to the creditor's own source of funds ('source of the source') was rejected as immaterial for that assessment year (pre-Finance Act 2022 amendment). The HC upheld the ITAT/CIT(A) conclusions on merits and rejected the revenue's reliance on assessment provisions under section 153A.
HC allowed the appeal of the assessee, holding that unsecured loan credited in AY 2014-15 was genuine and not exigible to addition under section 68. The Court found the identity and creditworthiness of the creditor established by bank records and statements recorded under survey and section 133(6); repayments (with interest) through banking channels in the subsequent year corroborated genuineness. The revenue's challenge to the creditor's own source of funds ('source of the source') was rejected as immaterial for that assessment year (pre-Finance Act 2022 amendment). The HC upheld the ITAT/CIT(A) conclusions on merits and rejected the revenue's reliance on assessment provisions under section 153A.
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