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...
Validity of search u/s 132 - place of search - the search conducted in the premises in which the assessee may not be carrying on the business would not nullify the search - ITAT was wrong in allowing appeal on the ground of search having been conducted in the premises not belonging to the assessee which is contrary to the tenor and language of Section 132
Validity of search u/s 132 - place of search - the search conducted in the premises in which the assessee may not be carrying on the business would not nullify the search - ITAT was wrong in allowing appeal on the ground of search having been conducted in the premises not belonging to the assessee which is contrary to the tenor and language of Section 132
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