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...
Unexplained cash credits u/s 68 - huge amount of cash deposited and withdrawal from bank - once the Revenue has not disputed that the assessee is engaged in construction business and no independent source of such cash receipts has been determined, the nature of such cash receipts can reasonably be treated as undisclosed business receipts and only net profit arising thereon can be brought to tax. - AT
Unexplained cash credits u/s 68 - huge amount of cash deposited and withdrawal from bank - once the Revenue has not disputed that the assessee is engaged in construction business and no independent source of such cash receipts has been determined, the nature of such cash receipts can reasonably be treated as undisclosed business receipts and only net profit arising thereon can be brought to tax. - AT
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