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...
Reopening beyond four years may be sustained where subsequent survey information indicates bogus purchase and sale transactions and the original assessment did not examine those transactions. Production of records does not establish full and true disclosure when the transactions themselves are allegedly non-genuine, and fresh information with a live nexus to income escaping assessment is not a change of opinion. For unproved business transactions, banking-channel payments alone do not prove genuineness without evidence of physical movement of goods. Where both purchases and corresponding sales are treated as bogus, income should be estimated by applying a gross-profit rate to turnover rather than adding the entire purchases, with credit for profit already disclosed.
Reopening beyond four years may be sustained where subsequent survey information indicates bogus purchase and sale transactions and the original assessment did not examine those transactions. Production of records does not establish full and true disclosure when the transactions themselves are allegedly non-genuine, and fresh information with a live nexus to income escaping assessment is not a change of opinion. For unproved business transactions, banking-channel payments alone do not prove genuineness without evidence of physical movement of goods. Where both purchases and corresponding sales are treated as bogus, income should be estimated by applying a gross-profit rate to turnover rather than adding the entire purchases, with credit for profit already disclosed.
Note: It is a system-generated summary and is for quick reference only.