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...
Additional depreciation claim @ 20% - the provision of section 32(1)(iia) is required to be interpreted reasonably and purposively as the strict and literal reading of section 32(1)(iia) will lead to an absurd result denying the additional depreciation to the assessee though admittedly the assessee has installed new plant and machinery. - HC
Additional depreciation claim @ 20% - the provision of section 32(1)(iia) is required to be interpreted reasonably and purposively as the strict and literal reading of section 32(1)(iia) will lead to an absurd result denying the additional depreciation to the assessee though admittedly the assessee has installed new plant and machinery. - HC
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