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 order of the ld. CIT(A) in material respects. Additions u/s 68 on account of sundry creditors were rejected, as identity, creditworthiness and genuineness were established through confirmations and statements, and the AO had proceeded merely on suspicion without summoning most creditors. In respect of unsecured loans, ITAT confirmed the sustained addition of Rs. 18,00,000/- relating to three depositors, as the assessee did not press her appeal; deletions for the remaining amounts were upheld. For expenses incurred in vacating encroachers, ITAT affirmed the ld. CIT(A)'s partial allowance by estimating payment at Rs. 2,500 per square yard and directing recomputation of cost of acquisition. Development expenses were allowed as per ld. CIT(A), the AO's reliance on an Inspector's belated and non-technical report being rejected. Revenue's grounds were dismissed.
ITAT upheld the order of the ld. CIT(A) in material respects. Additions u/s 68 on account of sundry creditors were rejected, as identity, creditworthiness and genuineness were established through confirmations and statements, and the AO had proceeded merely on suspicion without summoning most creditors. In respect of unsecured loans, ITAT confirmed the sustained addition of Rs. 18,00,000/- relating to three depositors, as the assessee did not press her appeal; deletions for the remaining amounts were upheld. For expenses incurred in vacating encroachers, ITAT affirmed the ld. CIT(A)'s partial allowance by estimating payment at Rs. 2,500 per square yard and directing recomputation of cost of acquisition. Development expenses were allowed as per ld. CIT(A), the AO's reliance on an Inspector's belated and non-technical report being rejected. Revenue's grounds were dismissed.
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