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...
Re-assessment u/ss 147 / 148 - no failure on the part of the Assessee to disclose fully and truly the relevant material resulting in such escapement of income in the form of either excess deductions or some additions or deductions u/s 36(1) - there is nothing on record to show that there was non-application of mind on the part of the AO in original assessment u/s 143(3) - reassessment not valid as it is mere case of change of opinion
Re-assessment u/ss 147 / 148 - no failure on the part of the Assessee to disclose fully and truly the relevant material resulting in such escapement of income in the form of either excess deductions or some additions or deductions u/s 36(1) - there is nothing on record to show that there was non-application of mind on the part of the AO in original assessment u/s 143(3) - reassessment not valid as it is mere case of change of opinion
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