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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Eligibility of a political party for exemption under s.13A was denied because it failed to substantiate statutory compliance, including timely return filing under s.139(4B), maintenance of audited books, and proper contribution reporting, and evidence showed donations were routed through bogus donors with cash returned after retaining 5-8% commission; exemption was therefore rejected. The addition of entire donations as unexplained cash credits under s.68 was held unsustainable since the receipts were identifiable as donation entries and deeming provisions could not be invoked merely because exemption was denied; the s.68 addition was deleted. However, the party's real income was held to be commission, directed to be assessed at 6% of total contributions as income from other sources under s.56(1). - ITAT
Eligibility of a political party for exemption under s.13A was denied because it failed to substantiate statutory compliance, including timely return filing under s.139(4B), maintenance of audited books, and proper contribution reporting, and evidence showed donations were routed through bogus donors with cash returned after retaining 5-8% commission; exemption was therefore rejected. The addition of entire donations as unexplained cash credits under s.68 was held unsustainable since the receipts were identifiable as donation entries and deeming provisions could not be invoked merely because exemption was denied; the s.68 addition was deleted. However, the party's real income was held to be commission, directed to be assessed at 6% of total contributions as income from other sources under s.56(1). - ITAT
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