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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In bogus purchase matters, the ITAT held that disallowance could not rest solely on search statements where section 133(6) notices were complied with and confirmations, returns and Form 16A were produced; with sales not treated as unexplained and the books not rejected, deletion of the major disallowance was upheld. For two parties that did not respond and did not furnish confirmations or returns, the Tribunal sustained only a 5% disallowance on the remaining purchases, without precedent effect. In the unexplained money issue, ticket sale receipts were duly explained on record, so deletion of the section 69A addition was confirmed. The Revenue's appeals failed.
In bogus purchase matters, the ITAT held that disallowance could not rest solely on search statements where section 133(6) notices were complied with and confirmations, returns and Form 16A were produced; with sales not treated as unexplained and the books not rejected, deletion of the major disallowance was upheld. For two parties that did not respond and did not furnish confirmations or returns, the Tribunal sustained only a 5% disallowance on the remaining purchases, without precedent effect. In the unexplained money issue, ticket sale receipts were duly explained on record, so deletion of the section 69A addition was confirmed. The Revenue's appeals failed.
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