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 allowed the Assessee's appeal and deleted additions made u/s 68. It held that the alleged unexplained cash credit, arising from unsecured loans and a difference in balances between the Assessee and the father, did not pertain to AY 2020-21; hence, the addition could not be sustained. Further, the Assessee had furnished sufficient documentary evidence establishing identity and creditworthiness of the lenders and genuineness of the loan transactions. The AO, despite remand proceedings, failed to bring any cogent material to discredit these documents and merely doubted creditworthiness. Uncontroverted evidence of loan repayments reinforced the Assessee's case. Consequently, all additions u/s 68 were deleted.
ITAT allowed the Assessee's appeal and deleted additions made u/s 68. It held that the alleged unexplained cash credit, arising from unsecured loans and a difference in balances between the Assessee and the father, did not pertain to AY 2020-21; hence, the addition could not be sustained. Further, the Assessee had furnished sufficient documentary evidence establishing identity and creditworthiness of the lenders and genuineness of the loan transactions. The AO, despite remand proceedings, failed to bring any cogent material to discredit these documents and merely doubted creditworthiness. Uncontroverted evidence of loan repayments reinforced the Assessee's case. Consequently, all additions u/s 68 were deleted.
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