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...
Accrual of income - effect of addendum of agreement - merely because in the original agreement, the parties had agreed to a higher sum by way of sale consideration, such amount cannot be stated to have accrued to the assessee, ignoring later developments reducing consideration due to slum in the business - income accrued based on revised terms.
Accrual of income - effect of addendum of agreement - merely because in the original agreement, the parties had agreed to a higher sum by way of sale consideration, such amount cannot be stated to have accrued to the assessee, ignoring later developments reducing consideration due to slum in the business - income accrued based on revised terms.
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