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...
Reopening of assessment u/s 147 - Deemed dividend - AO might have received aforesaid tangible information as to escapement of income chargeable to tax from records itself before it but the same is valid for invocation of provisions of Section 147 as there is no estoppel against law, more-so provisions of Section 147 are invoked within four years from the end of assessment year and proviso to Section 147 is not applicable .
Reopening of assessment u/s 147 - Deemed dividend - AO might have received aforesaid tangible information as to escapement of income chargeable to tax from records itself before it but the same is valid for invocation of provisions of Section 147 as there is no estoppel against law, more-so provisions of Section 147 are invoked within four years from the end of assessment year and proviso to Section 147 is not applicable .
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