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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Reopening of assessment challenged on the ground that reasons to believe lacked a live evidentiary link between seized materials and the assessee; the AO relied on statements and a brokers register suggesting a cash on money component and a unit rate, but those documents did not name the co-owner or the assessee. The AOs computation accepted the assessees 30% share, yet the asserted intent to sell the entire plot earlier conflicted with subsequent gift transactions by the co-owner. For lack of independent corroborative material connecting the assessee to the alleged on-money transaction, the impugned notice was quashed.
Reopening of assessment challenged on the ground that reasons to believe lacked a live evidentiary link between seized materials and the assessee; the AO relied on statements and a brokers register suggesting a cash on money component and a unit rate, but those documents did not name the co-owner or the assessee. The AOs computation accepted the assessees 30% share, yet the asserted intent to sell the entire plot earlier conflicted with subsequent gift transactions by the co-owner. For lack of independent corroborative material connecting the assessee to the alleged on-money transaction, the impugned notice was quashed.
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