Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
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Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
In transfer pricing comparability analysis for a manufacturing segment, the ITAT treated the Safe Harbour definitions of core and non-core auto components as a guiding aid for FAR analysis even though the assessee had not opted for Safe Harbour Rules. Because the assessee manufactured shock absorbers in the core auto component segment, only functionally similar comparables were acceptable. Helmet and accessory manufacturers, Eicher Motors, and Special Engineering Services were excluded for functional dissimilarity; Nifco was also excluded because its related party transactions exceeded 25%, despite otherwise being in the automotive component space.
In transfer pricing comparability analysis for a manufacturing segment, the ITAT treated the Safe Harbour definitions of core and non-core auto components as a guiding aid for FAR analysis even though the assessee had not opted for Safe Harbour Rules. Because the assessee manufactured shock absorbers in the core auto component segment, only functionally similar comparables were acceptable. Helmet and accessory manufacturers, Eicher Motors, and Special Engineering Services were excluded for functional dissimilarity; Nifco was also excluded because its related party transactions exceeded 25%, despite otherwise being in the automotive component space.
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