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...
TPA - ALP of payment of royalty u/s 92CA(3) - TPO instead of applying of the specified scientific methods went on to the justification of the purchase made in the context of the incremental benefit earned out of such know-how which was clearly not within his purview as he could not replace the assessee and question its business decision - payment within RBI approved limit - ALP accepted
TPA - ALP of payment of royalty u/s 92CA(3) - TPO instead of applying of the specified scientific methods went on to the justification of the purchase made in the context of the incremental benefit earned out of such know-how which was clearly not within his purview as he could not replace the assessee and question its business decision - payment within RBI approved limit - ALP accepted
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