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...
Disallowance u/s 40A - CIT(Appeals) restricted the rate of interest to 15% as against 18% claimed by the assessee - In the case of market loans, no security is given and no paper or other formalities are required to be completed. The unsecured loan is also available at the call and convenience of the assessee as and when required. - Entire interest expense allowed - AT
Disallowance u/s 40A - CIT(Appeals) restricted the rate of interest to 15% as against 18% claimed by the assessee - In the case of market loans, no security is given and no paper or other formalities are required to be completed. The unsecured loan is also available at the call and convenience of the assessee as and when required. - Entire interest expense allowed - AT
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