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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Loose sheets recovered in search can carry evidentiary value in income-tax proceedings when they contain contemporaneous transaction details and are fairly corroborated; the statutory presumption against the assessee applied, and a bare denial that the entries were not in the assessee's handwriting was insufficient to rebut it, so the additions based on undisclosed investment were sustained. Excess jewellery claimed as business stock failed on facts because neither the accounts nor wealth-tax returns showed it as stock-in-trade, so it was treated as undisclosed investment. Telescoping of unexplained cash was disallowed because the source of the cash was not satisfactorily established. The Tribunal's common order was upheld and the appeals were dismissed.
Loose sheets recovered in search can carry evidentiary value in income-tax proceedings when they contain contemporaneous transaction details and are fairly corroborated; the statutory presumption against the assessee applied, and a bare denial that the entries were not in the assessee's handwriting was insufficient to rebut it, so the additions based on undisclosed investment were sustained. Excess jewellery claimed as business stock failed on facts because neither the accounts nor wealth-tax returns showed it as stock-in-trade, so it was treated as undisclosed investment. Telescoping of unexplained cash was disallowed because the source of the cash was not satisfactorily established. The Tribunal's common order was upheld and the appeals were dismissed.
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