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...
Power and jurisdiction of Commissioner to amend eligibility certificate - If the Tribunal was competent to amend the eligibility certificate, then there is no reason why clerical and arithmetical errors, which are apparent on the face of the record for which no debate exists could not be corrected by the Commissioner under section 4A(3) - HC
Power and jurisdiction of Commissioner to amend eligibility certificate - If the Tribunal was competent to amend the eligibility certificate, then there is no reason why clerical and arithmetical errors, which are apparent on the face of the record for which no debate exists could not be corrected by the Commissioner under section 4A(3) - HC
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