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 dismissed the Revenue's appeal and upheld the assessee's stance, setting aside the addition under s.69. The Tribunal found the impugned WhatsApp screenshots unauthenticated, lacking any official signature or section 65B(4) certificate, and noted absence of the source device; thus the digital excerpts were inadmissible and susceptible to fabrication. The AO failed to obtain corroboration from Registration/Stamp Duty authorities, ignored the government-fixed stamp duty rate, and produced no comparable market evidence; the contested market-value computation appeared conjectural. No independent evidence of unexplained cash receipts was established, rendering the addition speculative and unsustainable.
ITAT dismissed the Revenue's appeal and upheld the assessee's stance, setting aside the addition under s.69. The Tribunal found the impugned WhatsApp screenshots unauthenticated, lacking any official signature or section 65B(4) certificate, and noted absence of the source device; thus the digital excerpts were inadmissible and susceptible to fabrication. The AO failed to obtain corroboration from Registration/Stamp Duty authorities, ignored the government-fixed stamp duty rate, and produced no comparable market evidence; the contested market-value computation appeared conjectural. No independent evidence of unexplained cash receipts was established, rendering the addition speculative and unsustainable.
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