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...
Proceedings u/s 153C - when there is a customary practice in this part of the country to give and receive gifts on the occasion of marriage, in the absence of any other investigation carried out by the department on the basis of the list of donors filed by the assessee, disallowing any part of the gift may not be justified - AT
Proceedings u/s 153C - when there is a customary practice in this part of the country to give and receive gifts on the occasion of marriage, in the absence of any other investigation carried out by the department on the basis of the list of donors filed by the assessee, disallowing any part of the gift may not be justified - AT
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