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 incriminating material seized in search sustains additions under section 153A - tribunal, following Benefit Tradelink, finds the issue against the assessee and dismisses the ground challenging additions. Addition as income under section 56(2)(vi) for amounts received as student fees - since receipts were offered to tax before the Settlement Commission and constituted student fees, section 56(2)(vi) is not attracted and no addition is warranted. Unexplained investment in property - pro rata contribution recomputed and limited to Rs.1,42,000, ground partly allowed. Purchase of specified land - amounts already offered before the Settlement Commission; no further addition. Stamp duty/registration expenses paid by relatives and not offered earlier - Revenue free to tax those amounts. - ITAT
Whether incriminating material seized in search sustains additions under section 153A - tribunal, following Benefit Tradelink, finds the issue against the assessee and dismisses the ground challenging additions. Addition as income under section 56(2)(vi) for amounts received as student fees - since receipts were offered to tax before the Settlement Commission and constituted student fees, section 56(2)(vi) is not attracted and no addition is warranted. Unexplained investment in property - pro rata contribution recomputed and limited to Rs.1,42,000, ground partly allowed. Purchase of specified land - amounts already offered before the Settlement Commission; no further addition. Stamp duty/registration expenses paid by relatives and not offered earlier - Revenue free to tax those amounts. - ITAT
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