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 upheld the finding that cash deposits made by Assessee A during the demonetization period were from own business sources, namely unorganized milk sales, but rejected the claim of substantial opening cash balance as unsubstantiated and self-serving, given absence of returns and audited books. ITAT concurred with CIT(A) that the entire cash deposits could not be treated as unexplained income and, considering the peculiar facts, sustained only 10% of the cash deposits as profit element, quantified at Rs. 74,800/-. ITAT further held that such income is taxable at normal slab rates and not under s.115BBE. The estimation and findings were directed not to operate as precedent for other assessment years.
ITAT upheld the finding that cash deposits made by Assessee A during the demonetization period were from own business sources, namely unorganized milk sales, but rejected the claim of substantial opening cash balance as unsubstantiated and self-serving, given absence of returns and audited books. ITAT concurred with CIT(A) that the entire cash deposits could not be treated as unexplained income and, considering the peculiar facts, sustained only 10% of the cash deposits as profit element, quantified at Rs. 74,800/-. ITAT further held that such income is taxable at normal slab rates and not under s.115BBE. The estimation and findings were directed not to operate as precedent for other assessment years.
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