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 an ad hoc 20% disallowance of truck rent expenses could not stand where the assessee had filed supporting details, sample invoices and vehicle registration papers, but the AO had not made proper verification, enquiries or rejected the books of account. As similar expenditure in the assessee's own earlier year had been restricted to 2% by a speaking order, and no distinguishing facts were shown, the disallowance was confined to 2%. The separate addition relating to unpaid motor truck rent was not upheld on the existing record and was remanded to the AO for verification after giving the assessee one further opportunity of hearing.
ITAT held that an ad hoc 20% disallowance of truck rent expenses could not stand where the assessee had filed supporting details, sample invoices and vehicle registration papers, but the AO had not made proper verification, enquiries or rejected the books of account. As similar expenditure in the assessee's own earlier year had been restricted to 2% by a speaking order, and no distinguishing facts were shown, the disallowance was confined to 2%. The separate addition relating to unpaid motor truck rent was not upheld on the existing record and was remanded to the AO for verification after giving the assessee one further opportunity of hearing.
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