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 u/s 271AAA - sufficient compliance - the language employed in the second exception under Explanation 5 to section 271(1) is, “pays the tax together with interest, if any, in respect of such income” and clause (iii) of sub-section (2) of section 271AAA employs the language “pays the tax, together with interest, if any, in respect of the undisclosed income”. Thus, the language employed in both the sections is similar - No penalty - HC
Penalty u/s 271AAA - sufficient compliance - the language employed in the second exception under Explanation 5 to section 271(1) is, “pays the tax together with interest, if any, in respect of such income” and clause (iii) of sub-section (2) of section 271AAA employs the language “pays the tax, together with interest, if any, in respect of the undisclosed income”. Thus, the language employed in both the sections is similar - No penalty - HC
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