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-firm's appeal substantially. It held that the surrender of excess cash and stock during survey was voluntary, in good faith, duly recorded in the regular books and returns, and fully covered the discrepancies; hence, no further addition was warranted on that account. Additions towards alleged unexplained investment in building construction, based solely on survey statement without any corroborative material or DVO reference, were deleted. The addition of Rs. 1 crore based on impounded slips showing temporary fund movements between the firm and partners was treated as mere circulation of excess liquid funds already covered by the Rs. 40 lakh surrender. Additions of Rs. 80 lakh for sundry debtors and Rs. 5.79 lakh on rejection of book results were also deleted.
ITAT allowed the assessee-firm's appeal substantially. It held that the surrender of excess cash and stock during survey was voluntary, in good faith, duly recorded in the regular books and returns, and fully covered the discrepancies; hence, no further addition was warranted on that account. Additions towards alleged unexplained investment in building construction, based solely on survey statement without any corroborative material or DVO reference, were deleted. The addition of Rs. 1 crore based on impounded slips showing temporary fund movements between the firm and partners was treated as mere circulation of excess liquid funds already covered by the Rs. 40 lakh surrender. Additions of Rs. 80 lakh for sundry debtors and Rs. 5.79 lakh on rejection of book results were also deleted.
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