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...
The assessee in first round surrendered income, which was retracted later, cognizance of which has not been taken either by the AO or the CIT(A). The onus is fully upon the assessee to explain with evidence as to the reason why it is retracting from its earlier disclosure of undisclosed income - AT
The assessee in first round surrendered income, which was retracted later, cognizance of which has not been taken either by the AO or the CIT(A). The onus is fully upon the assessee to explain with evidence as to the reason why it is retracting from its earlier disclosure of undisclosed income - AT
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