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 ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
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...
Functional comparability governs selection of software development support service comparables. Entities undertaking enterprise transformation, software-product or diversified activities, onsite services, product development or research and development, without reliable segmental information, do not meet the benchmark for routine software development support services and are excluded. The functional profiles of two proposed comparables require fresh examination. Inclusion of another comparable depends on verification of its related-party transaction computation under the applicable filter. Weighted-average operating margins and working-capital adjustments for software development and sales and marketing support services require verification and recomputation. Slump-sale gains and employee-benefit deduction claims also require factual verification, with interest and penalty issues following consequentially.
Functional comparability governs selection of software development support service comparables. Entities undertaking enterprise transformation, software-product or diversified activities, onsite services, product development or research and development, without reliable segmental information, do not meet the benchmark for routine software development support services and are excluded. The functional profiles of two proposed comparables require fresh examination. Inclusion of another comparable depends on verification of its related-party transaction computation under the applicable filter. Weighted-average operating margins and working-capital adjustments for software development and sales and marketing support services require verification and recomputation. Slump-sale gains and employee-benefit deduction claims also require factual verification, with interest and penalty issues following consequentially.
Note: It is a system-generated summary and is for quick reference only.