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...
Intimation u/s 143(1) as appealable order u/s 246A - CIT(A) had wrongly mentioned in the order reproduced herein above that no appeal lies against the intimation issued by the CPC under section 143( 1) of the Act unless the assessee approaches the CPC for rectification - there is no requirement in law to approach to the CPC for rectification of the order
Intimation u/s 143(1) as appealable order u/s 246A - CIT(A) had wrongly mentioned in the order reproduced herein above that no appeal lies against the intimation issued by the CPC under section 143( 1) of the Act unless the assessee approaches the CPC for rectification - there is no requirement in law to approach to the CPC for rectification of the order
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