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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Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
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