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...
Rejection of books of account under section 145(3) requires specific defects that prevent correct determination of business income; suspicion about cash receipts is insufficient where disclosed turnover and trading results remain undisturbed and computerised books and supporting records are offered for verification. Section 69A does not apply to money recorded in the books merely because the books are formally rejected. Cash deposits within recorded cash balances, arising from disclosed sales and trade-debtor realisations, cannot be assessed again as unexplained income unless their nexus with the recorded business is disproved. The section 69A addition was deleted, with consequential taxation under section 115BBE and penalty proceedings not surviving.
Rejection of books of account under section 145(3) requires specific defects that prevent correct determination of business income; suspicion about cash receipts is insufficient where disclosed turnover and trading results remain undisturbed and computerised books and supporting records are offered for verification. Section 69A does not apply to money recorded in the books merely because the books are formally rejected. Cash deposits within recorded cash balances, arising from disclosed sales and trade-debtor realisations, cannot be assessed again as unexplained income unless their nexus with the recorded business is disproved. The section 69A addition was deleted, with consequential taxation under section 115BBE and penalty proceedings not surviving.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
