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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Foreign contribution disclosed in the books and in the return of income could not be taxed merely because it was entered in Schedule-AI instead of Schedule-VC. The Tribunal held that there was no suppression of receipt, and the defect was only an inadvertent disclosure error in the wrong schedule. Denial of the charitable exemption claim solely on the ground that a revised return was not filed was unsustainable. The Revenue cannot collect tax beyond what is lawfully due merely because of an assessee's mistake in reporting. The impugned addition was deleted.
Foreign contribution disclosed in the books and in the return of income could not be taxed merely because it was entered in Schedule-AI instead of Schedule-VC. The Tribunal held that there was no suppression of receipt, and the defect was only an inadvertent disclosure error in the wrong schedule. Denial of the charitable exemption claim solely on the ground that a revised return was not filed was unsustainable. The Revenue cannot collect tax beyond what is lawfully due merely because of an assessee's mistake in reporting. The impugned addition was deleted.
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