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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
WhatsApp chats alone cannot sustain an addition treating part of an agreed consideration as unexplained investment; corroboration in seized material and statements is required and lacking here, so the addition under section 69 read with section 115BBE was deleted. The statutory presumption in favour of documents found during search must be applied by reading seized documents and recorded statements collectively; a holistic appraisal of draft agreements, estimates, board resolution and statements supported the taxpayer's position that the alleged cash related to a proposed refurbishment not carried out or paid. The Revenue failed to discharge the burden to establish unexplained investment.
WhatsApp chats alone cannot sustain an addition treating part of an agreed consideration as unexplained investment; corroboration in seized material and statements is required and lacking here, so the addition under section 69 read with section 115BBE was deleted. The statutory presumption in favour of documents found during search must be applied by reading seized documents and recorded statements collectively; a holistic appraisal of draft agreements, estimates, board resolution and statements supported the taxpayer's position that the alleged cash related to a proposed refurbishment not carried out or paid. The Revenue failed to discharge the burden to establish unexplained investment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
