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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Protective addition of the value of seized fine gold was impermissible once actual ownership was established. Since the owners of the seized gold were identified and had admitted ownership, and substantive assessment of the same asset was made in the hands of those real owners who undertook to discharge the tax liability, the assessee's mere status as a job worker could not justify a parallel protective addition. Accordingly, the protective addition in the assessee's hands was held invalid and was deleted, allowing the appeal. - ITAT
Protective addition of the value of seized fine gold was impermissible once actual ownership was established. Since the owners of the seized gold were identified and had admitted ownership, and substantive assessment of the same asset was made in the hands of those real owners who undertook to discharge the tax liability, the assessee's mere status as a job worker could not justify a parallel protective addition. Accordingly, the protective addition in the assessee's hands was held invalid and was deleted, allowing the appeal. - ITAT
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