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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The ITAT deleted the addition for alleged misclassification of interest income after finding that the assessee had disclosed total receipts, including foodgrain business receipts and Sharafi interest receipts, in the return computed under section 44AD. The Tribunal held that the amount treated as escaped income had already formed part of the disclosed aggregate turnover, so a separate addition would amount to duplication. It also noted that details such as the profit and loss account of the Sharafi business had been furnished before the AO, and that the books of account had not been rejected. On that basis, the AO's treatment was held unjustified and the addition was deleted.
The ITAT deleted the addition for alleged misclassification of interest income after finding that the assessee had disclosed total receipts, including foodgrain business receipts and Sharafi interest receipts, in the return computed under section 44AD. The Tribunal held that the amount treated as escaped income had already formed part of the disclosed aggregate turnover, so a separate addition would amount to duplication. It also noted that details such as the profit and loss account of the Sharafi business had been furnished before the AO, and that the books of account had not been rejected. On that basis, the AO's treatment was held unjustified and the addition was deleted.
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