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 appeal of Assessee X, deleting the addition made as unexplained money u/s 69A. The ITAT held that the cash deposits in the bank account represented business turnover already offered to tax under the presumptive scheme u/s 44AD, where maintenance of books is not mandatory and cash transactions are normal. It found that the AO and CIT(A) erred in treating the deposits as unexplained solely on the basis of bank credits, without considering corresponding withdrawals and the income already subjected to tax under the return filed u/s 44AD. Since legitimate tax had been paid on the turnover, no further tax liability survived. Consequently, the impugned addition u/s 69A was deleted and the ground of Assessee X was allowed.
ITAT allowed the appeal of Assessee X, deleting the addition made as unexplained money u/s 69A. The ITAT held that the cash deposits in the bank account represented business turnover already offered to tax under the presumptive scheme u/s 44AD, where maintenance of books is not mandatory and cash transactions are normal. It found that the AO and CIT(A) erred in treating the deposits as unexplained solely on the basis of bank credits, without considering corresponding withdrawals and the income already subjected to tax under the return filed u/s 44AD. Since legitimate tax had been paid on the turnover, no further tax liability survived. Consequently, the impugned addition u/s 69A was deleted and the ground of Assessee X was allowed.
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