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 - Unexplained cash receipt u/s 69A - The onus was on revenue to prove with corroborative evidence that the entries in the seized dairy actually represented the sales made by the assessee. Mere entries in the seized material was not sufficient to prove that the assessee has indulged in such a transaction - additions based on mere presumptions and assumptions and without any corroborative evidence could not be sustained.
Assessment u/s 153C - Unexplained cash receipt u/s 69A - The onus was on revenue to prove with corroborative evidence that the entries in the seized dairy actually represented the sales made by the assessee. Mere entries in the seized material was not sufficient to prove that the assessee has indulged in such a transaction - additions based on mere presumptions and assumptions and without any corroborative evidence could not be sustained.
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