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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Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
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