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...
Benami transactions - offence under Benami Act - onus of proving a benami transaction - after amendment, the onus of proving a benami transaction rests entirely on the shoulders of the respondents (Benamidar & beneficial owner) - Once both are able to discharge their burden of proof, then the burden of proof would be shifted to the prosecution - since IO has miserably failed to discharge such burden of proof - appeal is dismissed
Benami transactions - offence under Benami Act - onus of proving a benami transaction - after amendment, the onus of proving a benami transaction rests entirely on the shoulders of the respondents (Benamidar & beneficial owner) - Once both are able to discharge their burden of proof, then the burden of proof would be shifted to the prosecution - since IO has miserably failed to discharge such burden of proof - appeal is dismissed
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