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...
Admission of additional evidences u/r 46A - submitted first time before CIT(A) - The principles of natural justice are breached by learned CIT(A) by not calling for remand report from the AO as well non recording of reasons and justification for admitting the additional evidences - it is fatal to sustaining of appellate order passed by learned CIT(A)
Admission of additional evidences u/r 46A - submitted first time before CIT(A) - The principles of natural justice are breached by learned CIT(A) by not calling for remand report from the AO as well non recording of reasons and justification for admitting the additional evidences - it is fatal to sustaining of appellate order passed by learned CIT(A)
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