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...
Revision u/s 263 or appeal-able order before CIT(A) u/s 246A - Subject matter of revision was limited - Doctrine of merger - CIT(A) and ITAT rejected the appeal of assessee - appeal is maintainable in respect of the subject matter, which does not pertain to grounds u/s 263 of the Act. The CIT(A) therefore, ought to have adjudicated the appeal on merits to the aforesaid extent. - HC
Revision u/s 263 or appeal-able order before CIT(A) u/s 246A - Subject matter of revision was limited - Doctrine of merger - CIT(A) and ITAT rejected the appeal of assessee - appeal is maintainable in respect of the subject matter, which does not pertain to grounds u/s 263 of the Act. The CIT(A) therefore, ought to have adjudicated the appeal on merits to the aforesaid extent. - HC
Note: It is a system-generated summary and is for quick reference only.