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...
Penalty imposed u/s 271(1)(c) read with section 274 - It may be a good case for quantum addition but not for imposing penalty. Estimation is outcome of subjective approach of the individual. If we sustain the part penalty even after a huge surrender made by the assessee then the faith of the assessee will shake. Penalty deleted. - AT
Penalty imposed u/s 271(1)(c) read with section 274 - It may be a good case for quantum addition but not for imposing penalty. Estimation is outcome of subjective approach of the individual. If we sustain the part penalty even after a huge surrender made by the assessee then the faith of the assessee will shake. Penalty deleted. - AT
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