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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ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
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