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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On addition under s.68 r.w.s. 115BBE for an unsecured loan, the tribunal held that the loan stood established as genuine on parity with an earlier decision involving identical facts and allegations, and therefore deleted the addition. On addition under s.69A r.w.s. 115BBE for cash-in-hand treated as unexplained, it held that the cash was duly recorded in the books of multiple group entities and the source was thus explained; the deletion by the first appellate authority was upheld and the Revenue's ground was dismissed. On disallowance under s.37(1), it held that the AO made a double addition despite the assessee's own disallowance in computation; the deletion was sustained. - ITAT
On addition under s.68 r.w.s. 115BBE for an unsecured loan, the tribunal held that the loan stood established as genuine on parity with an earlier decision involving identical facts and allegations, and therefore deleted the addition. On addition under s.69A r.w.s. 115BBE for cash-in-hand treated as unexplained, it held that the cash was duly recorded in the books of multiple group entities and the source was thus explained; the deletion by the first appellate authority was upheld and the Revenue's ground was dismissed. On disallowance under s.37(1), it held that the AO made a double addition despite the assessee's own disallowance in computation; the deletion was sustained. - ITAT
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