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...
Bogus LTCG - addition u/s 68 - denial of exempt u/s 10(38) - AO has nowhere in the assessment order referred to any material which can prove the complicity of assessee in the alleged accommodation entry operation, hence in the light of the documents furnished by the assessee, the authorities below were not justified in invoking the provisions of section 68 in regard to the sale proceeds of shares - exemption allowable
Bogus LTCG - addition u/s 68 - denial of exempt u/s 10(38) - AO has nowhere in the assessment order referred to any material which can prove the complicity of assessee in the alleged accommodation entry operation, hence in the light of the documents furnished by the assessee, the authorities below were not justified in invoking the provisions of section 68 in regard to the sale proceeds of shares - exemption allowable
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