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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Bogus long-term capital gains additions on listed shares under section 68 cannot be sustained on suspicion alone where the assessee produces purchase records, demat statements, stock exchange sale documents and banking evidence, and the Revenue brings no specific rebuttal. The Tribunal held that general investigation inputs and allegations of penny stock accommodation entries do not displace documentary proof unless there is cogent material linking the assessee to a sham or manipulated transaction. On similar facts, including decisions involving the same scrip, the CIT(A)'s deletion of the addition was upheld and the Revenue's challenge failed.
Bogus long-term capital gains additions on listed shares under section 68 cannot be sustained on suspicion alone where the assessee produces purchase records, demat statements, stock exchange sale documents and banking evidence, and the Revenue brings no specific rebuttal. The Tribunal held that general investigation inputs and allegations of penny stock accommodation entries do not displace documentary proof unless there is cogent material linking the assessee to a sham or manipulated transaction. On similar facts, including decisions involving the same scrip, the CIT(A)'s deletion of the addition was upheld and the Revenue's challenge failed.
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