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...
Revision u/s 263 - The failure to compute assessee’s income u/s 115JB, in our considered opinion, would certainly make the order liable for exercise of revisional jurisdiction u/s 263. There was a certain omission on the part of Ld. AO in not considering the computation of Book Profits u/s 115JB and therefore, the jurisdiction u/s 263 was rightly invoked.
Revision u/s 263 - The failure to compute assessee’s income u/s 115JB, in our considered opinion, would certainly make the order liable for exercise of revisional jurisdiction u/s 263. There was a certain omission on the part of Ld. AO in not considering the computation of Book Profits u/s 115JB and therefore, the jurisdiction u/s 263 was rightly invoked.
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