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 dismissed Revenue's appeal and upheld the order of CIT(A) in toto. The Tribunal affirmed deletion of addition u/s 68 r/w s.115BBE on alleged unexplained sundry creditors, holding that only opening balances were involved and no fresh credit arose in the relevant previous year. Disallowance of GST expenditure was sustained as allowable business outgo, the liability having crystallized during the year when input tax credit had lapsed. On alleged bogus purchases, ITAT endorsed CIT(A)'s restriction of addition to a nominal gross profit rate, as books were audited, not rejected, and sales and stock records were accepted. Deletion of addition on alleged difference in purchases was also confirmed, the AO having miscompared net and gross figures.
ITAT dismissed Revenue's appeal and upheld the order of CIT(A) in toto. The Tribunal affirmed deletion of addition u/s 68 r/w s.115BBE on alleged unexplained sundry creditors, holding that only opening balances were involved and no fresh credit arose in the relevant previous year. Disallowance of GST expenditure was sustained as allowable business outgo, the liability having crystallized during the year when input tax credit had lapsed. On alleged bogus purchases, ITAT endorsed CIT(A)'s restriction of addition to a nominal gross profit rate, as books were audited, not rejected, and sales and stock records were accepted. Deletion of addition on alleged difference in purchases was also confirmed, the AO having miscompared net and gross figures.
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