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...
Rectification u/s 254 - non discussion of case law relied upon - it is not necessary for Court/Tribunal to discuss the case relied in the order as long the larger ratio rendered by the courts is not in conformity with the facts of the present case - assessee failed to make out a case of mistakes apparent on record - no rectification
Rectification u/s 254 - non discussion of case law relied upon - it is not necessary for Court/Tribunal to discuss the case relied in the order as long the larger ratio rendered by the courts is not in conformity with the facts of the present case - assessee failed to make out a case of mistakes apparent on record - no rectification
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