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...
Assessment u/s 153C - scope of amendment in Section 153C(1) - unless the documents or material seized ‘belonged’ to the Assessee, the assumption of jurisdiction u/s 153C qua such Assessee would be impermissible, the change brought about prospectively with effect from 1st June, 2015 by the amended Section 153C (1) did not apply to the search in earlier years
Assessment u/s 153C - scope of amendment in Section 153C(1) - unless the documents or material seized ‘belonged’ to the Assessee, the assumption of jurisdiction u/s 153C qua such Assessee would be impermissible, the change brought about prospectively with effect from 1st June, 2015 by the amended Section 153C (1) did not apply to the search in earlier years
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