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 the show-cause notice under section 24(1) was validly issued and whether the appellant discharged the burden to prove ownership of seized cash: the tribunal held that written "reasons to believe" were recorded prior to and incorporated in the notice as required by the statute and conveyed to the appellant, so the notice was valid; on the substantive issue the appellant failed to produce conclusive, legally admissible evidence (books of account, reliable third-party proof) to establish ownership or source of the cash, rendering explanations inconsistent and after-thoughts-consequence: the impugned order was upheld and no interference granted. - AT
Whether the show-cause notice under section 24(1) was validly issued and whether the appellant discharged the burden to prove ownership of seized cash: the tribunal held that written "reasons to believe" were recorded prior to and incorporated in the notice as required by the statute and conveyed to the appellant, so the notice was valid; on the substantive issue the appellant failed to produce conclusive, legally admissible evidence (books of account, reliable third-party proof) to establish ownership or source of the cash, rendering explanations inconsistent and after-thoughts-consequence: the impugned order was upheld and no interference granted. - AT
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