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...
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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's appeal, deleting the addition made by the AO on account of capital introduced in the business. ITAT held that duly executed agreements to sell agricultural land, evidencing full receipt of sale consideration, along with details of sellers, buyers, PAN, and photo identity, constitute a plausible and satisfactory explanation of the source of funds. It was held unjust for the AO to discredit these agreements merely due to non-execution of registered sale deeds, particularly in the context of joint landholdings and co-sharers where specific survey-wise conveyance may not be feasible. In the absence of any independent inquiry or rebuttal by the Revenue, the source of capital could not be doubted, and the addition was unsustainable.
ITAT allowed the assessee's appeal, deleting the addition made by the AO on account of capital introduced in the business. ITAT held that duly executed agreements to sell agricultural land, evidencing full receipt of sale consideration, along with details of sellers, buyers, PAN, and photo identity, constitute a plausible and satisfactory explanation of the source of funds. It was held unjust for the AO to discredit these agreements merely due to non-execution of registered sale deeds, particularly in the context of joint landholdings and co-sharers where specific survey-wise conveyance may not be feasible. In the absence of any independent inquiry or rebuttal by the Revenue, the source of capital could not be doubted, and the addition was unsustainable.
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