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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A prior unsuccessful revision under section 264 did not bar the assessee from pursuing the statutory appellate remedy, as the right of appeal is a substantive statutory right and no provision prohibited recourse to appeal after an earlier bona fide attempt at revision. The Tribunal also accepted sufficient cause for the delay before the first appellate authority and rejected the non-maintainability finding. On merits, cash deposits made during demonetisation were supported by bank records and supporting documents showing withdrawals for house construction and their later redeposit, so the addition under section 69A was held to rest on mere guesswork and was deleted.
A prior unsuccessful revision under section 264 did not bar the assessee from pursuing the statutory appellate remedy, as the right of appeal is a substantive statutory right and no provision prohibited recourse to appeal after an earlier bona fide attempt at revision. The Tribunal also accepted sufficient cause for the delay before the first appellate authority and rejected the non-maintainability finding. On merits, cash deposits made during demonetisation were supported by bank records and supporting documents showing withdrawals for house construction and their later redeposit, so the addition under section 69A was held to rest on mere guesswork and was deleted.
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