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...
Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
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