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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Addition under s.69A for cash deposits was challenged on the ground that the source was unproved. The assessee explained the deposits as arising from painting sales, sale of a portion of ancestral jewellery belonging to the mother supported by a valuation report, and cash gifts received by the son at his engagement, and furnished a cash-flow statement. The appellate authority accepted these explanations as consistent with ordinary human conduct and not disproportionate, and found the supporting evidence credible. As the Revenue only raised doubts on probabilities without rebutting the factual findings or evidence, interference was declined and deletion of the addition was upheld; the Revenue's appeal was dismissed - ITAT
Addition under s.69A for cash deposits was challenged on the ground that the source was unproved. The assessee explained the deposits as arising from painting sales, sale of a portion of ancestral jewellery belonging to the mother supported by a valuation report, and cash gifts received by the son at his engagement, and furnished a cash-flow statement. The appellate authority accepted these explanations as consistent with ordinary human conduct and not disproportionate, and found the supporting evidence credible. As the Revenue only raised doubts on probabilities without rebutting the factual findings or evidence, interference was declined and deletion of the addition was upheld; the Revenue's appeal was dismissed - ITAT
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