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...
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
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