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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Appeals against revision orders must identify a grievance with the revision itself. Grounds confined to a consequential assessment do not challenge the revision order. Where every ground targets only the consequential assessment, no maintainable challenge to the revision exists, and dismissal follows independently of any issue concerning delay in filing the appeal. This requirement ensures that appellate grounds correspond to the order purportedly under challenge rather than to a separate consequential assessment.
Appeals against revision orders must identify a grievance with the revision itself. Grounds confined to a consequential assessment do not challenge the revision order. Where every ground targets only the consequential assessment, no maintainable challenge to the revision exists, and dismissal follows independently of any issue concerning delay in filing the appeal. This requirement ensures that appellate grounds correspond to the order purportedly under challenge rather than to a separate consequential assessment.
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