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...
Penalty u/s 271(1) - addition of wrong claim u/s 80IB made by assessee in the return & surrendered during scrutiny proceedings - such claim is solely based on the report of auditor in Form No. 10CCB - Claim made by the assessee towards deduction u/s 80IB(4) is a bonafied mistakes, for which the penalty provisions provided u/s 271(1)(c) cannot be invited. - AT
Penalty u/s 271(1) - addition of wrong claim u/s 80IB made by assessee in the return & surrendered during scrutiny proceedings - such claim is solely based on the report of auditor in Form No. 10CCB - Claim made by the assessee towards deduction u/s 80IB(4) is a bonafied mistakes, for which the penalty provisions provided u/s 271(1)(c) cannot be invited. - AT
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