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. 69 for cash deposits during the demonetisation period was disputed on the ground that the deposits were already covered by additional income disclosed and taxed pursuant to settlement. The settlement order under s. 245D(4) recorded telescoping of cash balances of the assessee and a related trust against the additional income offered for earlier years, and the AO failed to show that such undisclosed income had been deployed elsewhere or that any outside-the-books investments existed. Applying the rule against double taxation of the same income and extending telescoping, the cash deposits were held explained out of previously taxed income, and no separate addition was sustainable; the Revenue's appeal was dismissed - ITAT
Addition under s. 69 for cash deposits during the demonetisation period was disputed on the ground that the deposits were already covered by additional income disclosed and taxed pursuant to settlement. The settlement order under s. 245D(4) recorded telescoping of cash balances of the assessee and a related trust against the additional income offered for earlier years, and the AO failed to show that such undisclosed income had been deployed elsewhere or that any outside-the-books investments existed. Applying the rule against double taxation of the same income and extending telescoping, the cash deposits were held explained out of previously taxed income, and no separate addition was sustainable; the Revenue's appeal was dismissed - ITAT
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