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 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.
Section 270AA immunity from penalty is unavailable where proceedings concern under-reporting arising from misreporting of income under Section 270A(9). A show-cause notice need not identify the precise misreporting subcategory where the assessment order has already disclosed the basis for treating the income as misreported; the notice is therefore not arbitrary or contrary to natural justice on that ground. As the immunity application falls outside the statutory framework, the Department is not required to decide it within the prescribed period. Objections based on denial of hearing and delayed disposal do not alter the rejection of immunity.
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