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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Addition for unexplained investment could not stand where it rested only on third-party statements and seized material from another group entity, without any independent corroborative evidence linking the assessee to payment of on-money. The Tribunal also noted that denial of cross-examination when such third-party statements are relied upon vitiates the addition in natural justice terms. Following co-ordinate Bench decisions on identical facts involving the same group, it deleted the addition under section 69 and allowed the assessee's appeals for the relevant years.
Addition for unexplained investment could not stand where it rested only on third-party statements and seized material from another group entity, without any independent corroborative evidence linking the assessee to payment of on-money. The Tribunal also noted that denial of cross-examination when such third-party statements are relied upon vitiates the addition in natural justice terms. Following co-ordinate Bench decisions on identical facts involving the same group, it deleted the addition under section 69 and allowed the assessee's appeals for the relevant years.
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