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 section 69 raised on a protective basis was set aside where seized third party material and statements did not explicitly prove cash 'on money' payments and the assessee denied such payments; ITAT held that reliance on limited third party evidence without corroboration is insufficient to attribute payments to the assessee. The tribunal also noted that a substantive addition against the closely connected brother had been deleted on merits by the first appellate authority, and therefore the protective addition against the assessee could not survive; appeal allowed.
Addition under section 69 raised on a protective basis was set aside where seized third party material and statements did not explicitly prove cash 'on money' payments and the assessee denied such payments; ITAT held that reliance on limited third party evidence without corroboration is insufficient to attribute payments to the assessee. The tribunal also noted that a substantive addition against the closely connected brother had been deleted on merits by the first appellate authority, and therefore the protective addition against the assessee could not survive; appeal allowed.
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