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...
Addition u/s 68 - proof of identity, creditworthiness and genuineness of the loan obtained - loans have been advanced by the companies through banking channels or from their own funds and there is no allegation of the AO that there was cash deposits in the bank accounts by these lenders before providing loans and there was no adverse information with the AO in respect of the lenders - no addition
Addition u/s 68 - proof of identity, creditworthiness and genuineness of the loan obtained - loans have been advanced by the companies through banking channels or from their own funds and there is no allegation of the AO that there was cash deposits in the bank accounts by these lenders before providing loans and there was no adverse information with the AO in respect of the lenders - no addition
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