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...
Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.
Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
