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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Whether addition under s.69 for alleged cash "on-money" paid for purchase of a shop could be sustained merely on statements recorded during search and an Excel sheet found in a third party's pen drive. The material on record, including allotment letter and bank statements, showed no evidence of any cash payment in AYs 2017-18 and 2018-19 and indicated that the purchase transaction occurred only in AY 2019-20; hence the s.69 additions for AYs 2017-18 and 2018-19 were deleted. For AY 2019-20, the statements and Excel sheet were held uncorroborated by independent evidence, consistent with co-ordinate bench precedents; hence the s.69 addition was deleted and the appeals were allowed - ITAT
Whether addition under s.69 for alleged cash "on-money" paid for purchase of a shop could be sustained merely on statements recorded during search and an Excel sheet found in a third party's pen drive. The material on record, including allotment letter and bank statements, showed no evidence of any cash payment in AYs 2017-18 and 2018-19 and indicated that the purchase transaction occurred only in AY 2019-20; hence the s.69 additions for AYs 2017-18 and 2018-19 were deleted. For AY 2019-20, the statements and Excel sheet were held uncorroborated by independent evidence, consistent with co-ordinate bench precedents; hence the s.69 addition was deleted and the appeals were allowed - ITAT
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