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...
Rule 68B's amended recovery period applies only where the original limitation period remained alive when the amendment took effect; recovery for 2007-08 and 2008-09 was therefore barred, while proceedings for 2009-10 to 2011-12 remained timely. Service on the defaulting firm sufficed for sale of its assets, particularly where partners received copies and participated; individual notice is required where recovery targets a partner's personal assets. Auction valuation was not defective because sale prices exceeded guideline and partner-declared market values, and revised reserve prices alone showed no undervaluation. Third-party funding of demand drafts did not invalidate compliant auction payments. The recovery auction was confirmed and the sale certificate was to issue to the purchaser.
Rule 68B's amended recovery period applies only where the original limitation period remained alive when the amendment took effect; recovery for 2007-08 and 2008-09 was therefore barred, while proceedings for 2009-10 to 2011-12 remained timely. Service on the defaulting firm sufficed for sale of its assets, particularly where partners received copies and participated; individual notice is required where recovery targets a partner's personal assets. Auction valuation was not defective because sale prices exceeded guideline and partner-declared market values, and revised reserve prices alone showed no undervaluation. Third-party funding of demand drafts did not invalidate compliant auction payments. The recovery auction was confirmed and the sale certificate was to issue to the purchaser.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
