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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT partly allowed the assessee's appeal in respect of addition for alleged bogus purchases treated as unexplained expenditure u/s 69C and taxed u/s 115BBE. While concurring that evidences of physical movement of goods were deficient, the Tribunal held that, given accepted corresponding sales and absence of rejection of books, only the profit element embedded in the disputed purchases could be taxed. Considering business nature, turnover and the assessee's concession, ITAT restricted the addition to 2% of the impugned purchases of Rs. 1,75,16,480/-, i.e., Rs. 3,50,330/-. It further held that such estimated profit does not fall under s.69C and is therefore taxable at normal rates, not u/s 115BBE.
ITAT partly allowed the assessee's appeal in respect of addition for alleged bogus purchases treated as unexplained expenditure u/s 69C and taxed u/s 115BBE. While concurring that evidences of physical movement of goods were deficient, the Tribunal held that, given accepted corresponding sales and absence of rejection of books, only the profit element embedded in the disputed purchases could be taxed. Considering business nature, turnover and the assessee's concession, ITAT restricted the addition to 2% of the impugned purchases of Rs. 1,75,16,480/-, i.e., Rs. 3,50,330/-. It further held that such estimated profit does not fall under s.69C and is therefore taxable at normal rates, not u/s 115BBE.
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