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 held that the assumption of jurisdiction u/s 153C was invalid as the seized document, being a copy of a ledger, did not "belong to" the assessee. The document merely recorded a transaction of Rs. 75 lakhs between two third parties, with no reference to the assessee-company. The satisfaction note by the AO incorrectly stated that the assessee had, by letter dated 16.06.2014, accepted the financial transactions reflected in the seized documents; in fact, the letter was filed by another group of companies which had owned the transactions. ITAT held that the AO failed to establish that the seized material pertained to, related to, or belonged to the assessee, and that such material had already been considered in the hands of the other group. Accordingly, the proceedings u/s 153C and the consequential additions were quashed.
ITAT held that the assumption of jurisdiction u/s 153C was invalid as the seized document, being a copy of a ledger, did not "belong to" the assessee. The document merely recorded a transaction of Rs. 75 lakhs between two third parties, with no reference to the assessee-company. The satisfaction note by the AO incorrectly stated that the assessee had, by letter dated 16.06.2014, accepted the financial transactions reflected in the seized documents; in fact, the letter was filed by another group of companies which had owned the transactions. ITAT held that the AO failed to establish that the seized material pertained to, related to, or belonged to the assessee, and that such material had already been considered in the hands of the other group. Accordingly, the proceedings u/s 153C and the consequential additions were quashed.
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