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 deposits were explained by debtor collections and past savings/opening balance, a factual explanation allegedly not properly examined by the AO/CIT(A). The matter was remitted to the AO for fresh verification on merits and decision in accordance with law. Separately, penalty under s.271B was upheld because the obligation to get accounts audited under s.44AB is independent of the obligation to maintain books under s.44AA, and levy of penalty under s.271A is not a precondition for penalty under s.271B; absence of audit justified confirmation of penalty. - ITAT
Addition under s.69A for cash deposits was challenged on the ground that the deposits were explained by debtor collections and past savings/opening balance, a factual explanation allegedly not properly examined by the AO/CIT(A). The matter was remitted to the AO for fresh verification on merits and decision in accordance with law. Separately, penalty under s.271B was upheld because the obligation to get accounts audited under s.44AB is independent of the obligation to maintain books under s.44AA, and levy of penalty under s.271A is not a precondition for penalty under s.271B; absence of audit justified confirmation of penalty. - ITAT
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