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 gifts credited through banking channels were not taxable under section 69A absent corroborative evidence that they represented the assessee's own unaccounted money, and the addition was deleted. Cash received as on-money on property sales could not be taxed as unexplained money under section 69A; it had to be included in sale consideration and assessed under capital gains. Additions based only on uncorroborated Excel sheets for alleged construction were rejected. Major jewellery additions were partly explained by family and customary gifts, with the balance sustained, and telescoping was allowed against confirmed on-money receipts. Cash found during search was sustained, but telescoping was granted. The watch-related addition was deleted on proof of ownership and independent verification.
ITAT held that gifts credited through banking channels were not taxable under section 69A absent corroborative evidence that they represented the assessee's own unaccounted money, and the addition was deleted. Cash received as on-money on property sales could not be taxed as unexplained money under section 69A; it had to be included in sale consideration and assessed under capital gains. Additions based only on uncorroborated Excel sheets for alleged construction were rejected. Major jewellery additions were partly explained by family and customary gifts, with the balance sustained, and telescoping was allowed against confirmed on-money receipts. Cash found during search was sustained, but telescoping was granted. The watch-related addition was deleted on proof of ownership and independent verification.
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