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 upheld rejection of the books of account because the assessee's cash sales, cash on hand and pre-demonetisation cash deposits showed an abnormal rise, while the supporting invoices were incomplete, generic and not backed by genuine evidence, so the accounts did not reflect a true and correct picture of business. On unexplained demonetisation-period cash deposits, the Tribunal accepted credit for the opening cash balance and bank withdrawals where no discrepancy was found, and sustained addition only for the balance amount remaining unexplained. It further held that the sustained addition under section 68 was taxable at the special rate under section 115BBE for AY 2017-18.
ITAT upheld rejection of the books of account because the assessee's cash sales, cash on hand and pre-demonetisation cash deposits showed an abnormal rise, while the supporting invoices were incomplete, generic and not backed by genuine evidence, so the accounts did not reflect a true and correct picture of business. On unexplained demonetisation-period cash deposits, the Tribunal accepted credit for the opening cash balance and bank withdrawals where no discrepancy was found, and sustained addition only for the balance amount remaining unexplained. It further held that the sustained addition under section 68 was taxable at the special rate under section 115BBE for AY 2017-18.
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