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...
Effect of amendment in Section 153C w.e.f .1st June, 2005 - law applicability on search prior to amendment and notice u/s 153C issued after amendment - amendment brings into its fold persons who are otherwise not covered by the said provisions and therefore, affects the substantive rights of such person - it was not permissible for the AO to assume jurisdiction u/s 153C amended w.e.f.01.06.2015 on searches carried out till 31st May 2015
Effect of amendment in Section 153C w.e.f .1st June, 2005 - law applicability on search prior to amendment and notice u/s 153C issued after amendment - amendment brings into its fold persons who are otherwise not covered by the said provisions and therefore, affects the substantive rights of such person - it was not permissible for the AO to assume jurisdiction u/s 153C amended w.e.f.01.06.2015 on searches carried out till 31st May 2015
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