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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Unexplained credit claims for a spousal gift were not accepted on the record because the assessee failed to produce contemporaneous bank statements or a clear mode of transfer and material discrepancies existed in the donor's tax schedules; the AO lacked effective opportunity to verify late-disclosed details. Applying the prima facie onus for unexplained credits, the Tribunal remitted the matter to the jurisdictional AO for fresh adjudication and directed the assessee to furnish complete documentary evidence and permitted factual verification before any addition is made.
Unexplained credit claims for a spousal gift were not accepted on the record because the assessee failed to produce contemporaneous bank statements or a clear mode of transfer and material discrepancies existed in the donor's tax schedules; the AO lacked effective opportunity to verify late-disclosed details. Applying the prima facie onus for unexplained credits, the Tribunal remitted the matter to the jurisdictional AO for fresh adjudication and directed the assessee to furnish complete documentary evidence and permitted factual verification before any addition is made.
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