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...
Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.
Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.
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